GI-2026-42-reg1: Non-Financial Activities (Banks and Bank Holding Companies) Regulations

Over 400 federally regulated financial institutions are affected, including banks, bank holding companies, federal credit unions, trust and loan companies, and insurers. Large banks (equity over $12 billion) face the strictest rules: non-financial activity revenues must stay under 10% of total revenue and capital exposure must stay under 10% of regulatory capital, plus they must file transaction reports within 30 days of each NFA investment and annual reports within six months of year-end — each requiring roughly 75–100 hours of professional finance staff time. Smaller and mid-sized banks (equity under $12 billion) get a higher revenue allowance of 15% and are fully exempt from reporting requirements, reducing their compliance burden significantly. The government estimates annualized compliance costs of about $98,000 for banks and bank holding companies, with total 10-year present value costs of roughly $691,000 — and conservatively assumes about 25% of small and mid-sized banks will actually use these new powers in any given year.