September 2025 Financial Reporting, Governance, and Risk Management
Message from Sydney Garmong, Partner, National Office
For those interested in the Federal Deposit Insurance Corp. (FDIC) proposal “Adjusting and Indexing Certain Regulatory Thresholds,” comments are due Sept 26. To date, the FDIC has posted 22 comment letters.
Last week, the Securities and Exchange Commission (SEC) posted its Spring 2025 Regulatory Agenda, which reflects “it is a new day” at the SEC, according to Chair Paul Atkins. Only four items are retained from the Fall 2024 agenda. The agenda also provides estimated timing for rulemaking.
Next week brings the American Institute of Certified Public Accountants (AICPA) banking conference and AICPA credit unions conference concurrently, Sept. 15-17, 2025, at the Gaylord National Resort & Convention Center, National Harbor, Maryland, just south of Washington, D.C.
This year is particularly special for the AICPA banking conference as 2025 marks the 50th year! During the conference, we will be looking back over the past 50 years in banking and milestones along the way.
It’s not too late to join us:
- The 2025 national AICPA & CIMA Conference on Banks & Savings Institutions. Use the code “BAN25” to save $100 on the in-person or the virtual option.
- The 2025 AICPA & CIMA Conference on Credit Unions. Use the code “CU25” to save $100 on the in-person or the virtual option.
If you join on-site, your registration includes access to two workshops on Sunday afternoon (3-5:30): “Fingers on the Keyboard: Chat GPT, Copilot, and AI Round Up” or “A Deep Dive Into Business Combinations.”
We will be reporting on the key themes and takeaways from both conferences.
Monday, Sept. 22 brings the beginning of fall and all things pumpkin. Thank you for turning to Crowe to keep you informed.
Financial Institutions Executive Briefing
Get updates on accounting, governance, risk management, and compliance issues.
From the federal financial institution regulators
FDIC reports slight dip in Q2 net income
On Aug. 26, 2025, the Federal Deposit Insurance Corp. (FDIC) reported that insured depository institutions posted a return on assets of 1.13% and aggregate net income of $69.9 billion in the second quarter, a slight decline from the prior quarter. The dip was driven largely by elevated provision expenses tied to the recently completed merger of Capital One and Discover. FDIC acting Chair Travis Hill noted that, excluding that one‑time cost, profitability would have increased amid higher net interest and noninterest income. In addition, domestic deposits rose for the fourth consecutive quarter, loan growth accelerated, and overall asset quality remained broadly favorable.
NCUA reports increase in Q2 net income
On Sept. 5, 2025, the National Credit Union Administration (NCUA) released its second quarter performance data for federally insured credit unions, showing an annualized increase of net income of 13.2% when compared to the same period in 2024. The report notes the U.S. credit union system continued to expand, serving more members and growing its overall assets and lending activity. While credit losses remained stable, delinquency rates increased slightly from the prior year. Members continued to add to their insured deposits, but the pace of loan growth slightly outstripped deposit growth. Overall, credit unions strengthened their financial position with higher net worth, improved earnings, and better margins, reflecting resilience despite some early signs of risk.
FDIC comment period closes soon on proposal to raise asset thresholds
As noted in our July briefing, the FDIC board approved a notice of proposed rulemaking to raise and index key regulatory thresholds, including those under 12 CFR Part 363, which is the regulation to implement Section 112 of the Federal Deposit Insurance Corporation Improvement Act of 1991 (FDICIA). The FDICIA subjects institutions above a certain asset size threshold to annual independent audits, assessments of the effectiveness of internal control over financial reporting, and compliance with designated laws and regulations, as well as related reporting requirements. It also includes requirements for audit committees. Many thresholds have not been updated in decades. The proposal would adjust the thresholds for cumulative inflation since adoption or last revision, with automatic reviews every two years or sooner if inflation exceeds 8%.
The proposal, “Adjusting and Indexing Certain Regulatory Thresholds,” was published in the Federal Register on July 28, 2025. Comments are due Sept 26. To date, the FDIC has posted 22 comment letters.
Fed announces capital requirements for large banks
On Aug. 29, 2025, the Federal Reserve (Fed) announced final individual capital requirements for large banks informed by stress-test results. The capital requirements provide a forward-looking and risk-sensitive assessment of capital needs and go into effect on Oct. 1, 2025.
Fed sunsets specialized novel-activities supervision
On Aug. 15, 2025, the Fed announced it will discontinue its Novel Activities Supervision Program – created in 2023 to oversee bank activities related to crypto assets, fintech, and distributed ledger technology – and reintegrate oversight within its standard supervisory protocols by rescinding Supervision and Regulation Letter 23‑7. The board cited its strengthened understanding of these emerging risks and noted the move reflects maturation of its supervisory approach, enabling more seamless monitoring of “novel” activities across all institutions.
FDIC board approves proposal to amend signage rules
On Aug. 19, 2025, the FDIC board of directors approved a proposed rule to revise requirements for displaying the FDIC official digital sign and related nondeposit disclosures. The changes aim to address operational challenges and consumer confusion stemming from a 2023 rule by allowing more flexibility in the design and placement of digital signage, limiting nondeposit warnings to dedicated product pages, and adjusting requirements for ATMs. The proposal sets a new compliance date of Jan. 1, 2027.
Comments are due Oct. 20, 2025.
From the Financial Accounting Standards Board (FASB)
FASB adds digital assets project to agenda
At its Aug. 13, 2025, meeting, the FASB announced the addition of a digital assets project to its research agenda. This initiative will evaluate potential targeted improvements to the accounting and disclosure requirements for certain digital assets and related transactions. Specifically, the project will examine 1) whether certain payment-oriented digital assets should be classified as cash equivalents, and 2) the accounting treatment of specific digital asset transfers, such as cryptocurrency lending arrangements. The research will incorporate input from stakeholders provided through the FASB’s 2025 Invitation to Comment: Agenda Consultation as well as recommendations outlined in the report issued by the President’s Working Group on Financial Markets regarding digital asset markets.
From the Securities and Exchange Commission (SEC)
SEC reveals regulatory agenda
On Sept. 4, 2025, Chair Paul Atkins announced availability of the SEC’s Spring 2025 Regulatory Flexibility Agenda. Atkins outlined the highlights of the agenda including a focus on crypto assets, capital formation, investor protection, and modernization of existing rules and regulations.
SEC updates C&DI on smaller reporting company status
On Aug. 27, 2025, the SEC’s Division of Corporation Finance issued a new Compliance and Disclosure Interpretation (C&DI) on the application of Rule 12b-2. The interpretation addresses the smaller reporting company revenue test in determining filer status changes and provides clarity on how issuers should evaluate their status over time, including how such determinations affect filer classifications for subsequent reporting periods.
SEC launches statistics and data visualizations webpage
On Aug. 13, 2025, the SEC announced a new webpage providing interactive statistics and data visualizations on capital markets activity.
Atkins noted that the goal of this initiative is to enhance transparency and accessibility for investors and the public. The resource includes information on IPOs, exempt offerings, bond issuances, and other market data, reflecting the commission’s broader efforts to make regulatory information more usable and support informed decision-making.
SEC names new enforcement director
On Aug. 21, 2025, the SEC announced the appointment of Judge Margaret Ryan as director of the Division of Enforcement, effective Sept. 2, 2025. Ryan’s career spans military, judicial, and private practice roles, including service as a senior judge on the U.S. Court of Appeals for the Armed Forces and as a partner at two law firms. She will lead the division’s enforcement program and oversee efforts to safeguard market integrity. She succeeds acting Director Sam Waldon, who will return to his prior position as chief counsel for the division.
From the Public Company Accounting Oversight Board (PCAOB)
PCAOB extends timeline for QC 1000 implementation
On Aug. 28, 2025, the PCAOB announced it is postponing the effective date of its new quality control standard, “QC 1000: A Firm’s System of Quality Control,” and related standards and rules by one year to Dec. 15, 2026. The delay also applies to the rescission of certain interim quality control and ethics standards, which will remain in force until that date. Importantly, the content of the standards and rules adopted in May 2024 remains unchanged, and firms may still choose to comply early (except as to reporting to the PCAOB on the evaluation of the quality control system). The PCAOB explained that the extension responds to feedback from firms reporting significant implementation challenges, concluding that the extra time will allow sufficient time to overcome these challenges.
PCAOB seeks nominations for IAG and SEIAG
On Aug. 20, 2025, the PCAOB announced it is seeking nominations for upcoming vacancies on its Investor Advisory Group (IAG) and Standards and Emerging Issues Advisory Group (SEIAG). Terms for the new members are two years, Jan. 1, 2026, through Dec. 31, 2027. Members provide critical perspectives to support the PCAOB’s mission of protecting investors and enhancing audit quality. Nominations are due Sept. 29, 2025.
FASB materials reprinted with permission. Copyright 2025 by Financial Accounting Foundation, Norwalk, Connecticut. Copyright 1974-1980 by American Institute of Certified Public Accountants.
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Fed explores new master account type, FASB issues PSL ASU, SEC chair outlines digital assets approach, CorpFin releases post-shutdown Q&A & more.
Get details of OCC and FDIC financial and reputation risk proposals, FASB internal-use software ASU, CorpFin government shutdown Q&A, and more.
Read about FDIC, NCUA Q2 industry data; Fed large bank capital requirements; FASB digital assets project; SEC reg flex agenda; PCAOB QC 1000 timeline.
Fed explores new master account type, FASB issues PSL ASU, SEC chair outlines digital assets approach, CorpFin releases post-shutdown Q&A & more.
Get details of OCC and FDIC financial and reputation risk proposals, FASB internal-use software ASU, CorpFin government shutdown Q&A, and more.
Read about FDIC, NCUA Q2 industry data; Fed large bank capital requirements; FASB digital assets project; SEC reg flex agenda; PCAOB QC 1000 timeline.