Davis Polk partner and Financial Institutions practice head Margaret Tahyar was quoted in Bloomberg Law discussing an FDIC memo instructing bank examiners to focus supervision on “material financial risks.”

The article noted that some individuals view the guidance as overly vague.

“It’s not as a problematic as it would be if they were imposing new requirements on banks,” Margaret said. “Here, the agencies are using their discretion to interpret an ambiguous and broad concept. And, critically, they are using it to instruct their own employees about supervisory priorities.”

“FDIC Tells Staff to Narrow Bank Examinations Ahead of Final Rule,” Bloomberg Law (January 12, 2026) (subscription required)

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