The Ads Are Gone. The Agenda Is Not.
By: Paul Schaus
November 10, 2026
Tomorrow is Veterans Day. Take a moment to thank those who serve and have served. These men and women defended the free elections and free speech that filled our screens for months, including every political ad that finally stopped last week. I will not miss them. The 2026 cycle set a record of more than $11 billion in political advertising, and 2028 will break it soon enough, so enjoy the quiet.
Some races are still being counted, and in Washington the jockeying for committee gavels has already begun. The question for a bank or credit union is not who wins those contests. It is what changes for the decisions already on your desk - the core renewal, the merger in diligence, the BaaS program in the pipeline. Here is my answer.
Democrats won control of both chambers. For banking technology, that is a change in political direction, not an immediate change in law. Most legislation still needs sixty votes in the Senate and a presidential signature, so the big structural bills face the same arithmetic that has stalled banking legislation for a decade.
What changes immediately is everything that does not require a floor vote: committee agendas, hearings, investigations, document requests, and the steady pressure a majority can put on regulators without passing anything.
The gavel, not the statute book, is where the next two years of banking technology policy will happen.
Senator Elizabeth Warren is poised to chair Senate Banking, though the selection is still pending. The House Financial Services gavel is genuinely contested: Maxine Waters, the committee’s former chair, faces a challenge from Sean Casten of Illinois, and Bill Foster was reported in October to be weighing one as well. How that contest resolves will say a great deal about whether the committee’s agenda runs on familiar lines or new ones.
The early signals are not about technology at all. Warren has already pressed regulators to withdraw three pending capital proposals and opposed the House-passed Main Street Capital Access Act, which would ease merger and supervisory requirements. For a community institution, read that as three practical facts.
First, the deregulatory window is narrowing. Proposals the agencies want finalized will move faster; proposals that need the next Congress’s tolerance will stall.
Second, merger review gets harder from here. Every delayed or abandoned deal is also a delayed or abandoned systems conversion, which is where M&A strategy and technology strategy are the same strategy.
Third, a revived CFPB agenda puts consumer-facing technology - fee presentation, data access, open-banking economics back on the examination horizon.
Beyond the bills, a majority’s real power is oversight by hearing: vendors, AI models, partnership programs, and outage post-mortems get a witness table and a camera. Bank technology executives have rarely testified before Congress. The companies that run their cores have almost never had to.
I would not bet on that continuing.
In “They Are Writing Your Next Exam Right Now,” I urged institutions to put their own experience into the record on the agencies’ proposed third-party risk management guidance and the joint statement on core service providers. The comment window closes Monday, November 16; an extension was requested, and none has been announced as of this writing. The election bears on that file in two ways.
First, the proposal is a loosening, written under a deregulatory executive order and the agencies will now finalize it knowing the committees watching them have changed hands. Expect hearings on whatever the final guidance says, and expect the “material risks” language to get more scrutiny from this Congress than it would have from the last one.
Second, and more concrete: Representative Bill Foster’s H.R. 10230, the Strengthening Oversight for the Financial Sector Act, would give the NCUA direct authority to examine the third-party vendors that serve credit unions. Authority the NCUA has requested for years, and the gap the Bank Service Company Act leaves open. Introduced in September, it was a perennial ask with a minority sponsor.
In January, its sponsor sits in the majority.
The industry is split. ICBA has long supported giving the NCUA parity with the banking agencies, while the Defense Credit Union Council argues the bill sweeps too broadly and that “regulatory authority is not, by itself, a cybersecurity control.” The council has a point about thresholds. But for credit unions, the practical question has shifted: it is no longer whether your critical vendors get examined, but by whom, how, and whether the findings reach you.
Our comment letter asked the agencies to share provider examination findings with client institutions. A Congress willing to extend examination authority is a Congress worth making that argument to.
If one business model should read the election results twice, it is banking-as-a-service. Sponsor banks were already living in the shadow of the Synapse collapse, where the question of whose ledger was right and whose customer was stranded went unanswered for months. The current proposal was written to remove barriers to innovation; the Congress overseeing it is led by members who built careers on the consumer-protection side of that trade.
Expect the BaaS questions to sharpen. They are the questions this series asks of every vendor relationship, pointed the other direction: whose ledger is authoritative, who reconciles it and how often, what the FBO account actually contains, and what happens to the end customer when the middleware company fails.
If your institution sponsors a program or is being pitched on the fee income, the election did not change the economics. It changed the audience. Program-level data rights, daily reconciliation you perform rather than receive, and an exit plan that does not strand someone else’s customers were good contract terms last month.
Next year they may be testimony.
The third agenda item needs no introduction. Expect sustained attention to AI in decisions that affect consumers - lending, credit limits, fraud flags, account closures - where the questions are adverse-action notices, explainability, and who answers when the model is the vendor’s.
This is not new law either. Regulation B already requires specific reasons for credit denials. What the election changes is the volume. If a vendor’s model makes or shapes customer decisions at your institution, the documentation that proves you can explain those decisions is about to be the most examined artifact in your technology stack, by examiners and committees alike.
Here is the comfort in all of it: the discipline does not change with the majority.
File your comment letter by Monday. The window closes whether or not an extension arrives, and the final guidance will now be defended in front of a different Congress, which makes the record more consequential, not less.
Keep the vendor file current - financial condition, contract terms, exit economics because every oversight scenario above lands first as a question to you, not to your vendor. Negotiate the same protections we have argued for all year: change of control, data extraction, and no exclusivity that forecloses your contingency plan.
If a merger is in your plans, assume a longer review and budget the conversion timeline accordingly. If BaaS fee income is in your plans, underwrite the oversight, not just the program.
And resist the urge to chase headlines. For a community institution, the binding constraint on technology was scale before the election, and it is scale after it. A new hearing schedule in Washington does not change which core conversions make sense in your market.
My final comment: elections change the questions bankers get asked; they rarely change the answers that matter. Everything a new Congress will want to know about your technology - who runs your core, what your contracts allow, whether your AI can explain itself, what happens if a vendor fails is something your examiners were already going to ask, and something this series has spent months helping you answer.
The ads are gone. The agenda is not. The institutions that will not mind are the ones whose vendor files already hold the answers before the hearing is scheduled.
CCG Catalyst advises banks, credit unions, and fintech companies on vendor strategy, contract negotiation, and regulatory readiness. If your institution is weighing what the new Congress means for its technology or business plans, reach out to our team at www.ccgcatalyst.com.
See our latest announcement: CCG Catalyst’s Paul Schaus Named a 2026 Top Consultant by Consulting Magazine
By: Paul Schaus | Founder & Managing Partner, CCG Catalyst Consulting
Disclaimer: The views expressed in this article represent the perspective of CCG Catalyst Consulting based on our direct experience advising financial institutions. This commentary is intended to stimulate industry discussion and does not constitute legal, accounting, or regulatory advice.
