United States: Finance and Banking

On March 31, the American College of Investment Counsel (ACIC) released comprehensive updates to all four Model Form Note Purchase Agreements used in domestic and cross-border private placement transactions.

The National Association of Insurance Commissioners (“NAIC”) held its 2026 Spring meetings in San Diego. The NAIC received updates from various working groups, including the RBC Investment Risk and Evaluation Working Group, Life RBC Working Group and the American Academy of Actuaries (“Academy”) on the proposals relating to capital charges (factors) for CLOs, Collateral Loans and other assets in order to refine and advance the regulatory framework governing capital treatment of such

On March 31, the Office of the Comptroller of the Currency (OCC) announced that it is amending Appendix E of 12 CFR 30 by rescinding "OCC Guidelines Establishing Standards for Recovery Planning by Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches" effective May 1. In addition, the OCC immediately rescinded Bulletins 2025-35, 2024-31, 2024-16, and 2018-47 relating to recovery planning.