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OCC March 2026 Enforcement Actions Summary

The OCC released its March 2026 enforcement actions, including one prohibition order against a former bank employee. The agency also terminated one consent order and three formal agreements with banks, citing full compliance with requirements, outdated provisions, or incorporation into new actions as reasons for termination.

Routine Enforcement Banking
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FCA proposes flexible suitability reviews, replaces annual requirement

The FCA published Consultation Paper CP26/10 on March 25, 2026, proposing to replace the current mandatory annual suitability review requirement for ongoing investment advice with a more flexible periodic review obligation. Under the proposed changes, firms providing investment advice to retail customers would determine review frequency based on client needs, risk profiles, and investment complexity, consistent with Consumer Duty obligations. Comments on the consultation close June 17, 2026.

Priority review Consultation Financial Services
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FDIC February Enforcement Actions - Consent Orders and Waiver Terminations

The FDIC published its February 2026 enforcement actions list on March 27, consisting of nine total actions: one consent order, one order of prohibition, six orders terminating 100 waiver orders, and one notice. The FDIC noted that no administrative hearings were scheduled for April 2026.

Routine Enforcement Banking
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California DFAL requires digital asset firms to obtain DFPI license by July 2026

California's Department of Financial Protection and Innovation (DFPI) requires digital asset businesses serving California residents to obtain a DFPI license by July 1, 2026 under the Digital Financial Asset Law (DFAL). Affected entities include exchanges, custodians, wallet providers, digital asset issuers, and crypto kiosk operators. Applicants must submit audited financial statements, maintain a minimum $500,000 surety bond, implement AML/BSA and KYC programs, align cybersecurity to NIST CSF 2.0, and provide customer disclosures.

Priority review Guidance Financial Services
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DOL Proposed Fiduciary Framework for 401(k) Investment Selection

The Department of Labor published proposed regulations on March 31, 2026, establishing a new framework and process-based safe harbor for fiduciaries selecting designated investment alternatives in 401(k) plans. The proposal addresses six factors (Performance, Fees, Liquidity, Valuation, Performance Benchmark, Complexity) and aims to reduce litigation risk for plan fiduciaries. Public comments are due by June 1, 2026.

Priority review Consultation Pensions & Retirement
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SEC Extends Trading Relief to Share Class ETFs

The SEC issued its fourth approval extending trading relief to share class ETFs, enabling these newly authorized ETF structures to begin listing and trading. The relief extends the broker-dealer exemptive provisions under Rule 6c-11 to share class ETFs, resolving a gap where brokers could not rely on existing relief for these instruments.

Routine Guidance Securities
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Financial Regulators' Adaptation to Fintech, AI, and Stablecoins

The House Financial Services Subcommittee on Digital Assets, Financial Technology, and Artificial Intelligence held a hearing examining how federal financial regulators are adapting to new technologies. Officials from the Fed, FDIC, OCC, and NCUA testified on their strategies for fostering innovation in AI, digital assets, and bank-fintech partnerships. The hearing also covered implementation of the GENIUS Act for payment stablecoins and the draft Financial Services Innovation Act of 2026.

Routine Notice Banking
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Strengthening Families Month Child Abuse Prevention Awareness

The Montana Department of Public Health and Human Services (DPHHS) announced the kickoff of Strengthening Families Month in April 2026, a statewide child abuse prevention awareness initiative. The Montana Children's Trust Fund will distribute over 12,000 blue pinwheels statewide, with over 71 organizations planning events including pinwheel plantings, family carnivals, and educational workshops. A kickoff event is scheduled for April 3 at Shodair Children's Hospital in Helena.

Routine Notice Public Health
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Governor Gianforte SNAP Junk Food Restriction Waiver Submission

Montana Governor Greg Gianforte submitted a waiver request to USDA Secretary Brooke Rollins to restrict SNAP purchases to nutritious foods, limiting purchases of soft drinks, candy, and junk food. The proposed demonstration project targets approximately 20 percent of SNAP spending currently used on unhealthy items and aligns Montana with 22 other states. The waiver introduces restrictions on beverages exceeding 10 grams of sugar per 8 ounces and establishes a standardized definition for candy and prepared desserts.

Priority review Consultation Public Health
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Montana Extends Pediatric RSV Immunization Through April

The Montana Department of Public Health and Human Services (DPHHS) issued a notice on March 18, 2026, recommending that healthcare providers continue offering RSV immunizations to eligible infants and young children through April 30, 2026. This extension addresses RSV activity that began circulating later than usual and continues to rise across Montana and the nation. The notice aligns with CDC recommendations for the groups most at risk, including infants under 8 months not yet immunized this season and high-risk children ages 8-19 months.

Routine Notice Public Health

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