Unknown UK Bank

SEC staff issued no-action relief on April 15, 2026, permitting a UK bank to exchange bailed-in bonds for equity shares without requiring registration under the Securities Act. SEC Chairman Atkins used the occasion to direct broader rulemaking to address registration hurdles that arise during foreign bank resolutions and failures. While this action is focused on a UK institution and cross-border resolution mechanisms rather than BaaS directly, it has implications for the broader bank resolution framework and how international banking partners — some of whom support embedded finance operations — handle failure scenarios. The rulemaking direction could eventually affect how US-regulated entities interact with foreign banking partners in BaaS contexts.

Verified from source: On April 15, 2026, SEC staff issued a no-action letter to the Bank of England confirming it would not recommend enforcement action if a UK banking organization exchanges bailed-in debt securities for ordinary shares without Securities Act registration. Chairman Atkins instructed staff to prepare broader rulemaking for an exemption from registration requirements in foreign bank bail-in resolutions.