Banking and Finance Law Daily Wrap Up, PRUDENTIAL REGULATION—GSIB Act of 2026 would provide investor-focused bank disclosures, (Feb 19, 2026)

By George M. Gullo, J.D.

The bill is intended as an investor- and consumer-oriented transparency initiative for the world’s largest bank holding companies.

Representative Ayanna Pressley (D-Mass.) has introduced legislation that would amend the Bank Holding Company Act to require each “global systemically important bank” (G-SIB) holding company to submit an annual report to the Federal Reserve Board, which would be required to make the report publicly available on its website. The Greater Supervision in Banking Act of 2026, co-sponsored by Reps. Al Green (D-Tex.) and Rashida Tlaib (D-Minn.) is intended as an investor- and consumer-oriented transparency initiative for the world’s largest bank holding companies.

In a press release, the bill’s sponsors present the legislation as a response to investor demand for useful information for decision making, citing areas such as diversity metrics, executive compensation practices, climate-related costs, and the transparency needed to hold G-SIBs accountable. The press release also lists endorsements from several advocacy organizations, underscoring the measure’s intended role in enhancing oversight of the largest bank holding companies.

Organizational footprint. The proposed legislation prescribes detailed organizational and footprint information, and builds on the existing regulatory definition of a “global systemically important bank holding company” in 12 C.F.R. §217.402. Each covered company must describe its activities during the preceding year and set out objectives and goals for the next year, anchoring the report in both retrospective and forward-looking disclosures.

Company disclosures. The bill would require companies to present their size and complexity, including a list of all subsidiaries and how each relates to specific business lines, and disclose the number and geographic distribution of branches for every depository institution subsidiary. They must also catalog all enforcement actions—including consent orders and settlements—against the company and its affiliates, expressly covering labor and health and safety violations in addition to consumer protection matters. They would also be required to quantify the number of consumers, employees, or investors harmed by the conduct underlying each action.

Accountability and conduct. Workforce accountability and market conduct are central themes in this bill. Firms must disclose the number of employees dismissed for misconduct, specifying whether any were executives. They also must describe capital-markets activities, including trading-desk structure and instruments; provide desk-level inventory statistics; explain how each desk complies with the Volcker Rule; and break down trading-account profit and loss, including fees, commissions, and spreads.

Shareholder rights. The Act extends coverage into shareholder rights and dispute-resolution. Reports must summarize shareholder rights under governing law and corporate instruments—covering:

• derivative suits;

• shareholder proposals;

• books-and-records access;

• scrutiny of conflicted transactions and cleansing mechanisms;

• standards for director independence and controlling shareholders; and

• presence of contracts granting governance rights.

Firms must also disclose the extent to which forced arbitration clauses are used in contracts with consumers, employees, investors, and contractors.

Compensation and governance. Disclosures related to compensation and governance are expansive. Companies must outline compensation and clawback policies and how they promote executive accountability, compare CEO and other senior-executive compensation to median employee pay, and describe any requirement that third-party vendors pay a minimum wage. They must provide average compensation by employee decile, state the firm’s minimum wage, and report how many employees earn it. Additional governance disclosures include board and senior-executive diversity, measures to promote workforce diversity and inclusion, and policies to expand the use of diverse contractors, including asset managers, brokers, and underwriters.

Technology oversight. Operational risk and technology oversight are also required by the report. Firms must describe their approach to cybersecurity and consumer-data protection and provide counts, topical breakdowns, and resolutions of internal whistleblower and ethics complaints over the prior year. They must explain investments in and uses of artificial intelligence, analyze benefits and risks for consumers, shareholders, climate, employees, and markets, and document how such risks are identified and mitigated, including pre-deployment testing, transparency reports, red-teaming, and security stress testing.

Environmental justice. Climate-related and environmental-justice disclosures are complex. Reports must discuss financed-emissions targets and whether they align with efforts to keep warming as close to 1.5°C as possible; reliance on offsets and their expected sources; the amount of financing in the last year (and commitments for future years) to companies involved in fossil-fuel expansion and any phase-out plans; and the projected effects of a 3°C-or-greater warming scenario on solvency, operations, and strategy. They must also address activities that contribute to or mitigate disproportionate environmental harms to communities of color and Indigenous peoples.

Community finance. Firms must disclose investments in, partnerships with, and support for minority depository institutions and community development financial institutions. For mergers and acquisitions completed during the prior year, firms must explain the effects on size and complexity; list branch closures; identify regional markets with changes in concentration using the Herfindahl-Hirschman Index; note changes in regional deposit shares; list the Federal or State agencies that approved each transaction; and describe any conditions imposed. Each report must also include a comparison showing how the company’s responses to the enumerated categories have changed over the last ten years. Finally, the Federal Reserve must publish these reports, including on its website, making the submissions broadly accessible to market participants and the public.

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