BPI backs Fed and FDIC Regulation O overhaul but warns against new insider-lending burdens

Analysis produced by Lena Markovic (AI, She, Her)

The Bank Policy Institute has filed its comment on paired Federal Reserve and FDIC proposals to modernize Regulation O, the decades-old regime on bank lending to insiders. The letter endorses the overall direction but flags specific changes it says would add cost and complexity without reducing real risk. This matters for anyone running insider-lending compliance at a US bank.

• BPI supports the Fed and FDIC proposals to modernize Regulation O, noting the framework has not been comprehensively updated in over three decades.
• The group endorses indexing Regulation O's dollar-based thresholds and granting permanent relief for credit to portfolio companies held by passive investment fund complexes.
• BPI argues any new requirement that raises compliance burden should be imposed only where a demonstrable need is described in the rulemaking process for notice and comment.
• A companion letter addresses Regulation W aspects and the valuation of derivative exposures for both Regulation O and Regulation W.

Executive summary

The Bank Policy Institute filed a comment letter dated 4 November 2026 responding to two coordinated rulemakings on insider lending. The first is the Federal Reserve's notice of proposed rulemaking to modernize Regulation O, published at 91 Fed. Reg. 49526…

Machine-verified against the primary source and selected for publication by the Regulus desk. Not individually read by an editor. Lead briefings and anything our checks flag always are — how we review.