The Risk Current: A New Regulatory Era, Digital-Asset Integration, and Signs of Strain.

March 2026

Mar 09, 2026

📡 The Risk Current. A series analyzing how evolving industry dynamics inform the work of risk and governance professionals.

Executive Summary

U.S. financial supervision is continuing its shift toward a new regulatory era focused more narrowly on material financial risks and less on governance and processes. Recent actions by regulators reflect efforts to streamline oversight and redefine “safety and soundness” around capital adequacy, liquidity resilience, and loss-absorbing capacity.

At the same time, regulators are opening the door for digital assets to move further into the regulated system through technology-neutral capital treatment for tokenized securities and more permissive signals around stablecoins. While the banking sector remains profitable, rising household debt and early liquidity pressures in the growing private credit market suggest potential stresses may be emerging at the margins.

For Financial Services Organizations (FSOs), the environment calls for sharper focus on financially material risks while maintaining strong governance and close monitoring of emerging risks, and the evolving role of digital assets.

Headline Updates

Continuation of the new regulatory era. As discussed in the November 2025 installment of The Risk Current, regulators are continuing to lean into a new, more relaxed supervisory era, narrowing their focus toward material financial risks and away from non-financial risks, governance and processes. In doing so, agencies are also taking the opportunity to define what safety-and-soundness means in practice; re-anchoring supervisory attention around risks that directly threaten capital adequacy, liquidity resilience, and the ability of FSOs to absorb losses during periods of stress. Developments across U.S. financial supervision in early 2026 reinforce this shift.
- The Federal Reserve Bank (FRB) is reviewing supervisory findings to ensure Matters Requiring Attention (MRAs) are tied to genuine safety-and-soundness concerns rather than process deficiencies, while temporarily holding stress-test capital requirements steady as elements of the framework are reassessed.12
- The Federal Deposit Insurance Corporation (FDIC) has advanced a broader “rightsizing regulation” agenda aimed at simplifying compliance requirements and revisiting aspects of fair lending examination and Community Reinvestment Act implementation.3
- The Office of the Comptroller of the Currency (OCC) has issued a final rule to amend its regulations to simplify licensing requirements for corporate activities and transactions involving national banks and federal savings associations that have less than $30 billion in total assets and satisfy certain conditions. The final rule is intended to reduce burden on these institutions.4
Taken together, these developments reinforce the ongoing recalibration of U.S. bank supervision toward financial materiality and operational flexibility.
Digital assets are moving deeper into the prudential mainstream. On March 5, 2026, the Fed, FDIC, and OCC jointly clarified that eligible tokenized securities generally receive the same capital treatment as their non-tokenized equivalents under the capital rules. The agencies explicitly described the framework as technology-neutral, while still requiring sound risk management. The same principle applies to collateral: The technologies used to confer legal rights to a security do not impact its ability to meet the definition of “financial collateral” in the capital rule.5
At the SEC, related policy signals are also becoming more permissive: on February 19, 2026, staff indicated they would not object to a broker-dealer applying a 2 percent haircut to proprietary positions in stablecoins under the net capital rule.6
A major legacy enforcement chapter has closed. On March 5, 2026, the Federal Reserve terminated its 2018 enforcement action against Wells Fargo after determining the bank had met all required conditions. The Fed said the remediation effort spanned nearly a decade. The asset cap had already been removed in 2025. Symbolically, this is an important marker of a broader regulatory climate that is becoming more willing to close out long-running supervisory matters once remediation is deemed sufficient.7
The U.S. banking industry remains profitable, but dark clouds are gathering on the horizon - the question now is whether we can navigate around the storm. FDIC-insured institutions reported a 1.24 % return on assets ratio and $77.7 billion of aggregate net income in Q4 2025. At the same time, New York FRB data released in February 2026 showed total household debt rising to $18.8 trillion, with higher mortgage, credit-card, auto, HELOC, and student-loan balances. Aggregate delinquency worsened to 4.8 percent, and serious delinquencies ticked up in several categories, including credit cards, mortgages, and student loans.89
Private credit shows early signs of liquidity strain. The private credit market, one of the fastest-growing sources of corporate financing over the past decade, may be showing the first subtle signs of stress. After Blue Owl restricted redemptions in one of its retail-focused credit vehicles, BlackRock recently capped withdrawals in its HPS Corporate Lending Fund after redemption requests exceeded the fund’s liquidity limits.
These actions highlight a structural tension in semi-liquid private credit vehicles, where investors may expect periodic liquidity despite the underlying loans being difficult to exit quickly. With the private credit market now estimated at roughly $2 trillion, and projected to hit $5 trillion by 2030, these developments have renewed debate around liquidity management, lending standards, valuation transparency, and whether emerging credit stresses may first appear outside the traditional banking system. While far from systemic, these episodes may represent early tremors worth watching as the credit cycle evolves.10

Drivers

The current moment is driven by a growing policy conviction that the supervisory approach has become overly process-heavy, opaque, and costly relative to the risks regulators now want to prioritize. In response, agencies are narrowing the definition of supervisory materiality, reducing documentation, filing burdens, and revisiting capital and liquidity rules.

Regulators are also signaling a preference to bring digital-asset activity inside the regulated perimeter rather than leaving it outside the system, as reflected in new guidance on tokenized securities, evolving treatment of stablecoins, and the OCC’s publication of digital-asset licensing applications.

At the same time, the macro backdrop remains stable but increasingly uncertain due to wars, supply-chain bottlenecks, and stress in some corners of the market.

Shifting Sentiment

Broadly, the industry is likely to welcome this direction. FSOs are seeing a supervisory environment that is becoming easier to navigate and more open to innovation in market infrastructure and digital assets. That combination lowers friction, improves optionality, and may support profitability and balance-sheet efficiency.

But the risks are not trivial. A narrower supervisory approach may not spot slow-building vulnerabilities that first show up as governance weakness, conduct issues, operational fragility, third-party concentration, or consumer harm before becoming financial loss. The same is true in digital assets: a technology-neutral capital posture may be sensible, but it does not eliminate legal, operational, liquidity, custody, fraud, and contagion risks.

Meanwhile, household debt and delinquency trends are a reminder that a relatively calm economic headline environment can still conceal localized deterioration.

What Do the Current Changes Mean for the Financial Services Industry?

FSOs should expect exams, remediation discussions, and supervisory dialogue to focus more tightly on what can be connected to capital, liquidity, solvency, or earnings resilience. Documentation that demonstrates this linkage will become more valuable than documentation that merely proves governance processes.
If supervisory findings are being reviewed and some MRAs are being downgraded or closed out, FSO may see less pressure to remediate issues that are connected to non-financial risk types. That creates room for prioritization, but also temptation to deprioritize foundational governance work that remains critical.
FSOs now have stronger signals that tokenized securities and stablecoins are moving toward operational legitimacy within regulated finance. Even FSOs not planning direct participation should reassess strategy, competitive positioning, and operational readiness.
Even with healthy bank profitability, the household side of the system is showing continued stress in selected areas. Similarly, private credit is showing signs of strain.
The direction of travel is toward simplification, narrower focus, and operational flexibility. FSOs should treat this not as a one-off adjustment, but as a new regulatory era.

Where FSOs Need to Remain Focused

Do not mistake reduced regulatory scrutiny for reduced risk. Non-financial risks can still lead to significant financial loss. Cybersecurity remains explicitly identified as a top priority by the FRB, and risks related to fraud, third-party dependencies, and operational resilience remain persistent and potentially consequential.
Do not treat tokenization as a passing fintech trend reserved for new entrants. It is increasingly a matter of business model, market infrastructure, custody, and governance. FSOs should assess their strategic readiness and operational capabilities to support these emerging rails.
The global environment is becoming increasingly complex and unpredictable, making vigilant monitoring of emerging risks and new drivers for existing risks a priority for FSOs.
Do not overreact to deregulation by dismantling governance. Policy direction can change again, and litigation, market events, fraud episodes, cyber incidents, or consumer-harm scandals can quickly reverse the current deregulatory mood. This is a moment for calibration, not abandonment.

Recommended Executive Actions

Focus documentation on risks and the risk response that pertain to capital adequacy, liquidity resilience, and the ability for FSOs to absorb losses during periods of stress. Ongoing and proactive regulatory engagement is key for navigating through these shifts.
Do not neglect non-financial risks or governance discipline. The broader governance architecture has played a critical role in preserving systemic stability. Collectively, these safeguards helped prevent contagion during the 2023 regional banking crisis, when capital markets remained wide and deep, particularly for the largest and most heavily regulated FSOs. The correlation is difficult to ignore; strong governance, layered oversight, and rigorous risk frameworks have historically reinforced financial resilience rather than distracted from it.
Run a tokenization and digital-assets readiness assessment. Even if the answer is “not now,” boards and executive teams should know what capabilities, constraints, and risks would matter if client expectations or competitive pressure change.
The resilience of households remains a key anchor of financial-system stability. While aggregate indicators remain broadly stable, cracks may begin to appear in specific segments of the credit ecosystem, particularly in less traditional markets such as private credit and other non-bank lending channels. Risk leaders should closely monitor household metrics, while also watch for spillover effects from geopolitical shocks, trade disruptions, or armed conflicts that could propagate through funding markets, commodity prices, or global liquidity conditions. Periods of stress often emerge at the margins before becoming everyone’s problem.

Conclusion

The regulatory environment for U.S. FSOs is entering a period of recalibration. Supervision is becoming more focused on financially material risks, while procedural and governance expectations receive comparatively less emphasis. This shift may create operational flexibility for FSOs, but it also places greater responsibility on FSOs to maintain disciplined risk management without relying solely on supervisory pressure. At the same time, emerging signals in household finances and private credit markets suggest that early stresses may be forming at the margins of the financial system. For risk leaders, the task ahead is clear: remain vigilant, maintain strong governance, and monitor where the next risks may surface.