We are looking forward to a holiday season filled with good cheer and time off with friends and family. In the meantime, it’s been a busy year (as usual) and a busy month. We hope you were able to attend one of our annual financial services client conferences in seven cities or our webcast on Dec. 16.
On Dec. 8-10, 2025, the American Institute of CPAs and the Chartered Institute of Management Accountants held the annual Conference on Current Securities and Exchange Commission and Public Company Accounting Oversight Board Developments in Washington, D.C., which some refer to as the annual nerd-fest. As good nerds do, we took notes and are providing a summary of key themes. And we are working diligently on a more robust document that will dive deeper into takeaways from the conference.
Over the past month, the Federal Deposit Insurance Corp. (FDIC) and the National Credit Union Administration issued reports on Q3 results. The FDIC approved a final rule to change and index certain regulatory asset thresholds, which mostly affects audit and internal control requirements. The federal banking agencies have been busy: the FDIC and the Office of the Comptroller of the Currency (OCC) withdrew guidance on leveraged lending, and the three agencies proposed changes to the community bank leverage ratio (CBLR). The OCC encouraged de novo charters, updated guidance on venture lending, reduced burden for community banks, and confirmed authority to hold crypto assets for network fees.
This year, the Financial Accounting Standards Board (FASB) focused on wrapping up its current agenda to be in a position to reload the agenda based on its 2025 invitation to comment, “Agenda Consultation.” The FASB has issued 12 Accounting Standards Updates (ASUs) in 2025 and should be finished for the year. If you’re curious, the last year the FASB issued 12 ASUs was 2019.
As we all prepare for a busy year-end financial reporting season, we wish you and yours a very happy and healthy new year.
The 2025 American Institute of CPAs (AICPA) and Chartered Institute of Management Accountants (CIMA) Conference on Current Securities and Exchange Commission (SEC) and Public Company Accounting Oversight Board (PCAOB) Developments held in Washington, D.C., Dec. 8-10 brought together leading stakeholders from regulatory bodies, standard-setters, and other groups to address the most pressing issues in financial reporting, auditing, and compliance. With a theme of “A Perfect Balance of Updates and Insights,” the conference highlighted evolving priorities across these groups in light of changes in leadership, emerging risks, and rapid technological developments as the profession looks ahead to 2026.
Chair Paul Atkins highlighted the pillars guiding his chairmanship, emphasizing a return to fundamental principles of financial reporting, including integrity, independence, and professional skepticism. He expressed concerns about the continued growth in disclosure volume and underscored the importance of financial materiality, noting that forthcoming rulemaking efforts aim to reduce burdens on public companies and improve conditions for IPOs. Atkins also discussed priorities related to crypto rulemaking to “give clear rules of the road” and addressed PCAOB oversight matters, including anticipated changes in board leadership and the selection of a new chair.
Chief Accountant Kurt Hohl spoke on the top priorities for the Office of the Chief Accountant (OCA), including emerging issues, oversight of the Financial Accounting Standards Board (FASB) and PCAOB, international standard-setting, and personnel development. He described ongoing evaluations of accounting firm structural changes, auditor independence considerations, and the effects of new technologies, specifically AI, on financial reporting. Hohl also highlighted coordination with the FASB on crypto-related matters to build a strong regulatory framework.
Personnel from the OCA discussed a variety of accounting hot topics the staff has addressed in the past year, including the derivative scope exception, private credit valuations, digital asset accounting, AI-related financial reporting risks, private equity investments in accounting firms, and auditor independence matters raised through consultations. The panel also discussed priorities related to international standard-setter engagement, including collaboration between the FASB and the International Accounting Standards Board and alignment of auditing standards of the PCAOB and the International Auditing and Assurance Standards Board.
Division of Corporation Finance (CorpFin) Director Jim Moloney provided an overview of priorities following the government shutdown. He noted that the staff is working diligently to address a backlog of more than 1,000 registration statements, with particular focus on processing capital-raising filings. Moloney also highlighted the division’s ongoing work on forthcoming rulemakings and planned roundtables, emphasizing the importance of broad stakeholder engagement as proposals move forward. He reiterated CorpFin’s focus on transparency and responsiveness, and he encouraged registrants to maintain open communication with the staff throughout the filing review process.
The CorpFin panel highlighted ongoing rulemaking efforts of the SEC, discussed significant staff transitions, and reiterated the staff’s focus on working through the backlog of registration statements. Key themes included updates to the Financial Reporting Manual and frequently observed issues in revenue recognition, segment reporting, non-GAAP measures, and MD&A disclosures. Staff emphasized the importance of clear, consistent application of reporting rules – particularly for segment expense disclosures, requirements related to special purpose acquisition companies (SPACs), accelerated filer status, and predecessor determinations in complex transactions. They also encouraged early consultation with CorpFin on interpretive questions and reminded registrants to avoid potentially misleading non-GAAP presentations. Overall, the message was one of transparency, careful compliance, and proactive engagement with the staff.
FASB Chair Rich Jones, Technical Director Jack Day, and Deputy Technical Directors Nellie Debbeler and Rosemarie Sangiuolo reported significant progress on completing existing technical agenda items and advancing projects arising from the 2025 agenda consultation. They noted strong stakeholder engagement – with 72 items identified through the consultation process. FASB leadership indicated that the board expects to address these consultation topics in public meetings by mid-2026.
Acting Chair George Botic emphasized the importance of the financial statement auditor’s role, highlighting the PCAOB’s inspection program, standard-setting activities, and transparency initiatives as core pillars supporting investor protection. He noted early indications of declining inspection deficiencies for 2025 and discussed the significance of standards such as internal control over financial reporting (ICFR) auditing and the quality control (QC) standard QC 1000, along with the value of Form AP, "Auditor Reporting of Certain Audit Participants," and critical audit matters (CAMs). Botic also addressed emerging opportunities and risks relating to artificial intelligence and outlined imperatives for auditors entering year-end audit cycles, including independence, skepticism, adequate resourcing, and CAMs evaluation.
PCAOB staff members held a panel discussion that covered recent inspection observations, noting improvements in audit quality and practices such as expanded specialist involvement, enhanced consultations, improved risk assessments, and strengthened client acceptance and continuance processes. Panelists reviewed the implementation timeline and available resources for QC 1000, enforcement priorities including independence violations, ethics matters, quality control deficiencies, and emerging issues related to technology-assisted audit procedures. They also highlighted the importance of sustained audit quality, appropriate use of AI, vigilance against fraud, and continued communication with PCAOB divisions through inspections, remediation processes, inquiry channels, and comment opportunities.
In keeping with the conference theme of a balance of updates and insights, the conference also included numerous discussions of AI, an economic update, and panel discussions on diverse topics including audit committee focus areas, legal perspectives, income taxes, tariffs, analyst and investor relations viewpoints, and the mergers and acquisitions landscape.
We will publish a comprehensive update in early January.
On Nov. 24, 2025, the Federal Deposit Insurance Corp. (FDIC) reported third quarter financial results for insured commercial banks and savings institutions. The report highlights increased net income, driven by lower provision expenses and improved net interest margins. The report also notes that asset quality metrics remain generally favorable but net charge-off rates remain above their pre-pandemic levels.
On Dec. 5, 2025, the National Credit Union Administration (NCUA) released its 2025 third quarter performance data for credit unions. The report highlights a notable increase in total net income for all credit unions since Q3 24 as well as continued loan growth. In addition, total delinquent loans and net charge-offs remain slightly elevated when compared to Q3 24.
On Nov. 25, 2025, the FDIC board of directors approved a final rule, “Adjusting and Indexing Certain Regulatory Thresholds.” The final rule updates certain regulatory thresholds to reflect historical inflation, including thresholds related to annual independent audits and reporting requirements under 12 Code of Federal Regulations (CFR) Part 363. The rule also calls for future threshold adjustments based on an indexing methodology.
Under the final rule, 12 CFR 363, which regulates Sec. 112 of the FDIC Improvement Act (FDICIA), is amended, in part, as follows:
The thresholds continue to be measured using total assets as of the beginning of the fiscal year and will be indexed to inflation, generally measured every two years. The final rule does not allow for downward indexing – only upward.
If an IDI will no longer be subject to Part 363 requirements under the updated thresholds in effect as of Jan. 1, 2026, the final rule provides immediate regulatory relief by clarifying that such an institution is not required to comply for any open fiscal year prior to the effective date of the final rule.
For more information, see the Crowe article “FDIC Final Rule Adjusts and Indexes Regulatory Thresholds.”
On Dec, 5, 2025, the Office of the Comptroller of the Currency (OCC) and the FDIC jointly withdrew their 2013 leveraged-lending guidance and related 2014 FAQ. In doing so, the agencies emphasized that banks engaged in leverage lending remain responsible for managing associated risks consistent with general principes for safe and sound lending, including a clearly defined risk appetite, consistent underwriting, independent assessments of exposure, and continuous monitoring of borrower performance and risks to refinancing.
On Nov. 25, 2025, the FDIC, OCC, and Federal Reserve Board (Fed) jointly issued a final rule reducing the enhanced supplementary leverage ratio for large depository-institution subsidiaries, capping the enhanced supplementary leverage ratio standard at 1% with an overall requirement for these institutions of no more than 4%. The agencies estimate overall capital levels will remain broadly unchanged for banking. The final rule takes effect April 1, 2026, with optional early adoption on Jan. 1, 2026.
On Nov. 25, 2025, the FDIC, OCC, and Fed jointly issued a notice of proposed rulemaking to revise the community bank leverage ratio for certain qualifying community banks, lowering the required ratio from 9% to 8% and extending the out-of-compliance grace period from two quarters to four. The change aims to reduce regulatory burden and give community banks more flexibility in capital management while maintaining safety and soundness.
On Dec. 1, 2025, the Fed issued its semiannual “Supervision and Regulation Report,” outlining banking conditions and supervisory priorities. The report notes that the financial condition of banking organizations is broadly stable. Key risk considerations and areas of supervisory focus include commercial real estate exposures and softening consumer lending segments, market risk from unrealized positions, and increasing reliance on short-term wholesale funding at some institutions.
On Nov. 18, 2025, the Fed released new supervisory operating principles designed to focus examiners on material financial risks and enhance clarity through supervisory findings. The updated framework, which has been distributed to supervisory leadership and staff, is intended to align examination and rating processes with real financial risk, reduce duplication across examinations, and streamline remediation of identified problems.
On Dec. 16, 2025, the OCC issued its “Semiannual Risk Perspective” for the second half of 2025. The report notes that the national banking system remains sound with strong capital and liquidity, despite some softening of multifamily commercial real estate metrics. The report also focuses on the opportunities presented by financial innovation as well as emerging risks, such as the increase in cybersecurity threats posed by foreign state-sponsored actors and cybercriminal groups.
On Dec. 8, 2025, Comptroller of the Currency Jonathan Gould delivered remarks at the Blockchain Association Policy Summit emphasizing the OCC’s renewed commitment to de novo bank chartering including charters for entities engaged in digital asset activities as a way to promote competition innovation and a more dynamic banking system. Gould stressed that the OCC will fairly and rigorously evaluate and supervise both new entrants and incumbents to ensure that innovation occurs within a safe, sound, and legally compliant federal banking framework.
On Dec. 5, 2025, the OCC updated its guidance on venture loans to commercial entities in an early, expansion, or late stage of corporate development. The update rescinds prior 2023 guidance and notes that banks are not discouraged from prudent venture lending activities, provided those activities align with their risk appetite, are maintained within established limits, supported by sound underwriting, appropriately risk-rated, and sufficiently reserved to reflect the higher uncertainty and risk of default.
On Nov. 24, 2025, the OCC announced a package of supervisory and regulatory measures aimed at reducing burdens on community banks. The actions include tailored Bank Secrecy Act/anti-money laundering (BSA/AML) examination procedures reflecting community banks’ generally lower risk for money laundering and terrorist financing, discontinuation of the money laundering risk data-collection system, and a new request for information to assess the challenges community banks face with core service providers.
On Nov. 18, 2025, the OCC confirmed that national banks may, as part of the business of banking, hold crypto assets on their balance sheet as principal for the purposes of facilitating blockchain network fees (for example, gas fees) when required to facilitate otherwise permissible activities. The interpretive letter also allows banks to hold small amounts of crypto assets for testing crypto asset platforms, provided the activity is safely managed and appropriately limited.
On Dec. 4, 2025, the Financial Crimes Enforcement Network (FinCEN) released a financial trend analysis outlining recent ransomware payment patterns identified through BSA reporting. The report emphasizes increased use of virtual assets and layered transactions to obscure funds and encourages institutions to incorporate these typologies and red flags into their monitoring programs.
As of Dec. 1, 2025, FinCEN’s Residential Real Estate Rule is fully effective. The rule mandates reporting of certain nonfinanced transfers of residential property involving legal entities and trusts.
On Nov. 21, 2025, FinCEN issued a notice summarizing Financial Action Task Force (FATF) updates to its lists of jurisdictions with strategic AML/countering the financing of terrorism (CFT)/countering the financing of proliferation of weapons of mass destruction (CPF) deficiencies. The advisory reinforces expectations for institutions to factor these designations into risk assessments, due diligence, and monitoring, particularly where customer or transaction exposure involves listed jurisdictions.
On Nov. 13, 2025, FinCEN announced findings identifying financial transactions linked to the Sinaloa cartel’s global revenue generation and money laundering networks. The analysis highlights how cartel-connected actors use front companies, cash-intensive businesses, and layered wire transfers to move funds through U.S. and international channels. FinCEN emphasized that institutions should review the listed typologies and red flags to strengthen monitoring for sanctions-evasion and narcotics-related illicit finance.
On Dec. 8, 2025, the FASB issued Accounting Standards Update (ASU) 2025-11, “Interim Reporting (Topic 270): Narrow-Scope Improvements,” which clarifies and reorganizes interim reporting guidance without changing the underlying disclosure requirements. The ASU confirms that Topic 270 applies to all entities that issue interim financial statements under GAAP, creates a comprehensive list of required interim disclosures, and introduces a disclosure principle requiring companies to report events after year-end that materially affect interim results. The ASU also clarifies the form and content of interim financial statements, including when condensed statements are appropriate.
For public business entities (PBEs), the ASU is effective for interim periods within fiscal years beginning after Dec. 15, 2027. For all other entities, it is effective for interim periods within fiscal years beginning after Dec. 15, 2028. Early adoption is permitted.
On Dec. 4, 2025, the FASB issued ASU 2025-10, “Government Grants (Topic 832): Accounting for Government Grants Received by Business Entities,” providing comprehensive guidance for business entities that receive government grants. The standard establishes recognition, measurement, and presentation requirements for monetary and tangible nonmonetary grants, defines what qualifies as a government grant, and sets a probable threshold for recognition based on both compliance with grant conditions and likelihood of receipt. The ASU requires entities to classify grants as asset-related or income-related, with asset-related grants accounted for using either a deferred income approach or a cost-accumulation approach, and income grants recognized systematically over the periods of related costs. Expanded annual disclosures are required, including information about grant terms, accounting policies, and, for nonmonetary grants, the fair value recognized.
The standard is effective for PBEs for fiscal years beginning after Dec. 15, 2028, and one year later for all other entities, with early adoption permitted.
For more information, see the Crowe article “FASB Issues Final ASU on Government Grants for Businesses.”
On Nov. 25, 2025, the FASB issued ASU 2025-09, “Derivatives and Hedging (Topic 815): Hedge Accounting Improvements,” introducing targeted changes to better align hedge accounting with real-world risk management activities. The ASU broadens when forecasted transactions can be pooled through a new “similar risk exposure” criterion, creates an optional model for hedging interest payments on choose-your-rate debt, expands component hedging for nonfinancial forecasted transactions using the clearly-and-closely-related principle, allows certain swap-and-option combinations to qualify as eligible hedging instruments, and corrects presentation issues in dual hedging strategies involving foreign-currency-denominated debt.
The guidance is effective for PBEs for fiscal years beginning after Dec. 15, 2026, and one year later for all other entities, with early adoption permitted and prospective application required, with some flexibility.
For more information, see the Crowe article “FASB Issues Hedge Accounting Improvements.”
On Nov. 20, 2025, the FASB released its Post-Implementation Review Report on Leases (Topic 842), concluding that the standard generally meets its objective of providing investors with more transparent and useful information about leasing activities. The report reflects outreach to more than 1,600 stakeholders and notes that while lessor accounting has operated smoothly with minimal cost, lessees incurred significantly higher than expected implementation and ongoing compliance costs, primarily due to system and process changes needed to recognize operating leases on the balance sheet. Although the post-implementation review is complete, the FASB emphasized that it will continue monitoring application of the standard and will consider future improvements as needed.
At its Nov. 19, 2025, meeting, the FASB added a project to its technical agenda to address accounting for crypto asset transfers, including wrapped and receipt tokens, by expanding the scope of Subtopic 350-60 and clarifying when control of a crypto asset is surrendered for derecognition. With this addition, and a separate project on cash-equivalent classification of certain digital assets, the FASB removed its broader digital assets research project. Remaining digital-asset issues will be evaluated through future agenda consultations.
On Dec. 5, 2025, Corp Fin announced updates to the Financial Reporting Manual to reflect amendments related to SPACs, shell companies, and projections, which were effective July 1, 2024.
On Dec. 3, 2025, Commissioner Mark Uyeda delivered remarks at the Institute for Corporate Counsel outlining the SEC’s focus on rules that encourage more companies to go public and stay public. His remarks discussed reassessing periodic reporting requirements and potential changes to quarterly reporting, transparency in the SEC’s regulatory framework, and considerations related to mandatory arbitration provisions in registration statements. Uyeda also noted the importance of evaluating proxy voting practices under existing beneficial ownership rules.
On Dec. 2, 2025, Atkins delivered a major policy address, “Revitalizing America’s Markets at 250,” laying out the SEC’s vision for modernizing U.S. capital markets as the country approaches its 250th anniversary. The address underscored regulatory reforms centered on promoting capital formation, improving market efficiencies, and ensuring the U.S. remains a competitive market.
On Nov. 17, 2025, the SEC’s Division of Examinations released its annual 2026 examination priorities, signaling key areas of focus for the coming year including fiduciary duty, standards of conduct, custody rule compliance, and adherence to recent amendments such as the 2024 updates to Regulation S-P. Atkins noted that examinations are a critical component of the SEC’s mission to protect investors, emphasizing that the process is not intended to be a “gotcha exercise.”
On Dec. 4, 2025, the SEC announced the second virtual outreach event for registrants impacted by the 2024 updates to Regulation S-P on Dec. 17, 2025. This session focuses on transfer agents. Staff from the Division of Examinations and the Division of Trading and Markets review new obligations under the amended rule, discuss what firms should expect during SEC examinations, and answer outstanding compliance questions.
On Dec. 4, 2025, Atkins delivered remarks addressing corporate governance priorities, the SEC’s ongoing evaluation of distributed ledger technology and tokenization in capital markets, and the potential need for regulatory updates to accommodate on-chain models. Atkins also noted that existing principles-based disclosure requirements already obligate companies to provide material information regarding the use and impact of artificial intelligence.
The SEC updated its filing fee disclosure taxonomy on Nov. 20, 2025, refining the classification framework used for fee categories under various registrations and filings. Refer to the published update available under Standard Taxonomies on the SEC’s website.
On Nov. 21, 2025, the SEC announced a Dec. 16 roundtable hosted by the University of Austin to discuss potential reforms to Rule 611 under Regulation NMS. The SEC invites public comment through electronic submission or by mail.
On Nov. 20, 2025, Division of Trading and Markets Director Jamie Selway delivered remarks at a Securities Industry and Financial Markets Association (SIFMA) conference emphasizing the importance of rebuilding trust in the marketplace while integrating emerging “trustless” digital assets. Selway highlighted Atkins’ Project Crypto initiative and noted that the division is engaging widely with market participants as it evaluates policies to support innovation. The remarks underscored that competition and clear regulatory frameworks remain central to fostering well-functioning markets and reiterated the SEC’s commitment to restoring trust between the public and private sectors.
In a Nov. 20, 2025, speech at Baruch College’s 20th Annual Audit Conference, PCAOB acting Chair George Botic emphasized the enduring responsibility of auditors to protect investors and uphold integrity in the capital markets, even as the profession undergoes rapid change. Botic pointed to two developments reshaping the audit landscape: the rise of private equity investment in accounting firms, which introduces both new resources and new pressures, and the accelerating use of artificial intelligence, which offers potential efficiencies but also raises questions about bias, transparency, and how to maintain professional judgment. Against this backdrop, he underscored the need for a shared, modern definition of audit quality that reflects independence, technical expertise, audit execution, and the impact of audit outcomes on market confidence. Botic encouraged stakeholders, practitioners, academics, and investors to help shape this definition, noting that a unified view of audit quality could strengthen the entire financial reporting ecosystem and guide the profession through technological and structural change.
In remarks at the World Continuous Auditing and Reporting Symposium on Nov. 7, 2025, board member Christina Ho emphasized that the audit of the future will look fundamentally different as rapid advances in artificial intelligence and data technologies reshape the profession. Drawing on insights from the PCAOB’s Technology Innovation Alliance (TIA) Working Group, Ho outlined four strategic priorities for building a tech-forward audit environment: promoting standardized and structured audit data to support AI-driven analysis, encouraging responsible adoption of AI tools that can enhance audit coverage and quality, strengthening regulatory innovation through experimentation and collaborative innovation labs, and elevating technology literacy across the auditing workforce. She stressed that the profession’s role as a guardian of trust is becoming even more critical in an era of misinformation and that future auditors will need both technical expertise and the courage to uphold integrity in increasingly complex environments.
On Nov. 6, 2025, PCAOB board member Kara Stein presented remarks to the Portuguese Securities Market Commission and stressed that effective audit firm leadership is essential as technology, market dynamics, and firm structures evolve. She emphasized the importance of culture, independence, and robust quality control systems in navigating challenges such as AI-enabled financial reporting, private equity involvement in audit firms, new forms of digital assets, and talent pipeline pressures. Stein noted that audit quality indicators can support governance, but ultimately, integrity and sound judgment remain the foundation of high-quality auditing.
The Office of the Investor Advocate on Nov. 18, 2025, released an investor bulletin explaining how PCAOB inspections help protect investors by evaluating audit firms’ compliance with standards and the effectiveness of their quality control systems. The bulletin outlines which firms are inspected, highlights 2024 activity, and points readers to resources explaining how inspections are conducted and how to access public inspection reports.
On Dec. 2, 2025, the PCAOB announced that Ho will conclude her service on the board on Jan. 31, 2026, or earlier if the SEC names a successor. During her tenure, she chaired the TIA Working Group, collaborating with external experts on emerging technologies, and was recognized by Botic for championing innovation as a driver of improved audit quality.
The CAQ on Nov. 17, 2025, released its Fall 2025 Audit Partner Pulse Survey, which captured audit partners’ perspectives gathered in September and October on economic conditions, regulatory pressures, and emerging business risks. The survey indicates that economic sentiment is stabilizing, with pessimism declining significantly and more partners adopting a neutral or cautiously optimistic outlook. Regulatory uncertainty and trade tensions have become the most significant risks facing companies, leading many businesses to expand disclosures related to strategy, financial performance, and the integration of artificial intelligence. Cost management continues to be a central focus as companies reduce head count, refine hybrid work policies, and selectively upskill employees. At the same time, the use of artificial intelligence continues to grow, most notably in process automation, customer support, and predictive analytics, reflecting a belief that long-term resilience will depend on targeted technology investment.
Portions of AICPA materials reprinted with permission. Copyright 2025 by AICPA.
FASB materials reprinted with permission. Copyright 2025 by Financial Accounting Foundation, Norwalk, Connecticut. Copyright 1974-1980 by American Institute of Certified Public Accountants.