Alex here.

This is Lex Reg Pulse Daily for Wednesday, April 29, 2026.

Three federal banking rules publish today, the Senate Banking Committee has advanced Kevin Warsh's Federal Reserve chair nomination to a floor vote, and OFAC's Iran sanctions architecture expanded materially yesterday.

The operational clock is running on all three fronts.

Start with the rules, because they carry hard dates.

The OCC published two interim final rules today, both effective June 30.

The first blocks Illinois's Interchange Fee Prohibition Act from applying to national banks and federal savings associations.

The state law would have restricted interchange fees on tax and gratuity portions of transactions.

The OCC's order resolves that conflict in favor of federal authority.

Comment period closes May 29.

The second OCC rule confirms that national banks retain full discretion to charge non-interest fees, including interchange fees, even when those fees are set by or negotiated with third parties such as card networks and processors.

One clarification worth noting: the rule creates authority, not a safe harbor.

Institutions considering new fee structures should complete a UDAAP — Unfair, Deceptive, or Abusive Acts or Practices — analysis before implementation.

The third rule is the interagency Community Bank Leverage Ratio update, finalized jointly by the OCC, Federal Reserve, and FDIC.

Effective July 1, the minimum leverage ratio drops from 9% to 8%, implementing the statutory floor established in the 2018 Economic Growth, Regulatory Relief, and Consumer Protection Act.

The rule also extends the grace period for institutions temporarily falling below the threshold — from two consecutive quarters to four, with a maximum of eight quarters in any five-year period.

Qualifying institutions, those with less than ten billion dollars in total consolidated assets, should recalculate capital positions against the revised threshold before July 1.

On the leadership transition: the Senate Banking Committee voted Wednesday to advance Kevin Warsh's nomination as Federal Reserve chair.

A full Senate floor vote is now days away.

The Federal Open Market Committee holds rates today — that decision carries no signal given the consensus expectation of a hold.

Jerome Powell's press conference at 2:30 p.m.

Eastern is widely expected to be his final as chair.

The planning variable for large bank holding companies is not rate policy.

It is supervisory posture.

Warsh has explicitly distinguished monetary policy independence from supervisory approach.

Examination intensity, capital adequacy framing, and the regulatory relationship with large institutions are the scenario variables worth modeling now.

On Iran sanctions: OFAC designated 35 entities and individuals on April 28 under what it calls the "Economic Fury" action, targeting private financial intermediaries — known as "rahbar" networks — that manage shell company structures used by sanctioned Iranian banks, including Bank Sina, Bank Sepah, and Bank Mellat, to access international financial markets.

Separately, OFAC issued a formal alert on Chinese independent oil refineries in Shandong Province — known as teapot refineries — noting that some have directly accessed the US financial system for dollar-denominated transactions and US goods procurement.

For US banks with correspondent relationships in the Asia-Pacific region, that direct access means the exposure is not theoretical.

OFAC also published FAQ 1249, which extends sanctions exposure to payments made to Iran or the Islamic Revolutionary Guard Corps for passage through the Strait of Hormuz.

Shipping finance and trade finance teams should analyze that scope carefully — it is novel.

Two deadlines close Thursday, May 1.

The OCC's proposed rule on national bank stablecoin issuance and the FinCEN and OFAC proposed rule extending anti-money laundering and sanctions obligations to stablecoin secondary market activity both close simultaneously.

These are separate submissions with separate analytical demands.

The secondary market AML scope in the FinCEN and OFAC rule is the higher-complexity filing.

Also effective Thursday: the OCC's rescission of its recovery planning requirements.

Institutions that have not assessed whether internal frameworks compensate for the removed structure are out of time.

For the full analysis, check your Lex Reg Pulse daily briefing in your inbox, or catch Lex Reg Pulse Weekly every Sunday.

I'm Alex.

This has been Lex Reg Pulse Daily.

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