Daily · Banking Reclassifications and US Credit Shifts · August 25, 2026

Shifts in Credit and Banking Status

The European Banking Authority (EBA) has launched a consultation on revised technical standards concerning the reclassification of investment firms as credit institutions. For firms operating in the investment space, this is a high-priority window to assess how these standards will affect the process of transitioning to a banking license, which fundamentally alters their regulatory obligations and operational scope. Meanwhile, in the US, the Office of the Comptroller of the Currency (OCC) has made effective the rescission of the Interagency Statement on Special Purpose Credit Programs under the Equal Credit Opportunity Act and Regulation B. While the substantive decision was made on February 22, 2022, the rescission takes effect today, meaning creditors must now implement updated compliance procedures regarding these specific credit programs. Our read: This represents a dual push toward redefining institutional boundaries in Europe and refining credit accessibility rules in the US.

US Sanctions and Market Infrastructure

OFAC has expanded its Specially Designated Nationals and Blocked Persons (SDN) List, adding new persons and vessels. Compliance teams must immediately update their screening filters to prevent prohibited transactions with these newly designated entities to avoid severe enforcement actions. Simultaneously, the SEC has issued several updates targeting US trading venues and clearinghouses. These include the approval of new on-boarding policies for Credit Default Swap (CDS) instruments at ICE Clear Credit LLC, amendments to the data sources used by the Nasdaq Stock Market LLC, and the implementation of enhanced activity-based risk controls for IEX Options Members. While these changes are technical and limited to the specific participants of these exchanges, firms utilizing these platforms should monitor the updates to ensure their trading systems align with the new risk and data protocols.

This overview is informational, not legal or compliance advice. Consult your lawyer or compliance specialist on specific decisions.

Sources

This overview is based on official regulator publications for the period:

EU (1)

UK (2)

US (7)