By Anna Kooi, Financial Services & Financial Institutions Leader, Wipfli
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The Omnibus Banking and Business Bill (OBBB) is shaping up to be the most significant U.S. financial reform since Dodd-Frank. But the real story isn’t in the legislative headlines; it’s in the ripple effects about to hit operations, strategy, and competitive positioning for banks, fintechs, insurers, and wealth managers.
For some, this will be a scramble to adjust compliance frameworks. For others, it’s the opening they’ve been waiting for. Drawing from recent regulator commentary, industry group analyses, and surveys of banking leaders, here are five areas where the OBBB could change the game.
1. Crypto clarity and custody: Regulation meets readiness
For years, traditional institutions hesitated to move into crypto because there was no clear federal playbook. The OBBB finally offers one: The Commodity Futures Trading Commission (CFTC) will regulate crypto commodities, while the Securities and Exchange Commission (SEC) will oversee crypto securities.
That clarity matters. It could open doors to:
- Custody and settlement services for digital assets, something about one in four banks already offer in some form
- Stablecoin issuance and tokenized deposits, a potential growth channel that aligns with moves proposed under the Stablecoin TRUST Act
- Wealth advisory in crypto, giving registered investment advisers a defined path to custody, recommend, or manage crypto portfolios under fiduciary standards
But no one gets a free pass. With fraud and financial crime detection ranking as the top AI application for financial institutions in multiple industry surveys, tech and compliance will have to work hand-in-hand to make these services viable.
2. Regulatory modernization: Relief for some, risk for others
One of the bill’s quieter but potentially most impactful changes is its risk-tiered supervision model. In theory, if you’re well-capitalized and well-managed, you’ll spend less time buried in redundant reports. For banks under $10B in assets, that’s a big deal.
Here’s the reality check: Smaller institutions are far less likely to have the enterprise risk management (ERM) programs regulators expect for “well-managed” status. Recent data shows that while 76% of banks overall have ERM, the number drops to just 34% for those under $500M in assets.
Another piece to watch is M&A. S&P Global Market Intelligence reports that U.S –bank deal activity is already up 18% year-over-year. Combine that with looser OBBB merger rules, and the industry could see a new wave of consolidation, especially among institutions looking for scale to absorb compliance costs.
3. Bank-fintech collaboration: A higher bar for BaaS
Banking-as-a-service (BaaS) and embedded banking have been hot growth strategies. The OBBB will test just how sustainable they are by tightening vendor management and third-party oversight rules.
For banks sponsoring fintechs, expect:
- More rigorous onboarding and partner vetting
- Stronger AML/KYC protocols
- Regular operational resilience testing
This mirrors the OCC’s 2024 guidance urging “continuous monitoring” of fintech relationships. The banks that invest now in cybersecurity will not only meet the standard for BaaS but stand out for their reliability.
4. Fiduciary expansion and transparency: More advisors in scope
The OBBB broadens the fiduciary definition under ERISA and the SEC’s Regulation Best Interest (Reg BI), pulling more wealth advisors into heightened disclosure and conflict-of-interest requirements.
This will hit a fast-growing service line. Wealth advisory ranks among the most commonly added offerings in recent years, according to the American Bankers Association’s wealth management survey. Firms will need to strengthen compliance controls, update advisor training, and ensure they can monitor conflicts in real time.
5. Carried interest reform: Deal timelines in flux
Changes to carried interest taxation could extend holding periods and alter deal structures, with ripple effects for private equity, investment funds, and the banks that serve them. The Private Equity Growth Capital Council has warned that these shifts could cool deal volume in some sectors.
Layer in persistent net interest margin pressure, and it’s clear that capital allocation and transaction timing will need fresh modeling under the new rules.
The takeaway
The OBBB is a pivot point, not just another compliance task list. Institutions that move early — tightening governance, building more resilient fintech partnerships, and using regulatory clarity to enter emerging markets like digital assets — can turn the bill’s requirements into an advantage.
We don’t often see regulation move ahead of innovation. This time, it is. And the players who adjust fastest will define the industry’s next chapter.
