The OCC is restoring its former practices and policies under the Bank Merger Act to reinstate expedited merger reviews and streamlined business combination applications....more
5/19/2025
/ Acquisitions ,
Bank Merger Act ,
Banking Sector ,
Biden Administration ,
Expedited Actions Process ,
Financial Institutions ,
Interim Final Rules (IFR) ,
Mergers ,
OCC ,
Rescission ,
Trump Administration
The federal banking agencies continue to open the channels for regulated entities to engage in digital asset activities.
On May 7, 2025, the Office of the Comptroller of the Currency (OCC) published Interpretive Letter...more
5/12/2025
/ Banking Sector ,
Banks ,
Cryptocurrency ,
Custody ,
Digital Assets ,
Financial Institutions ,
Interpretive Letters ,
New Regulations ,
OCC ,
Outsourcing ,
Regulatory Requirements ,
Risk Management
FRB eases crypto restrictions on supervised entities in alignment with the new administration’s support for the digital asset industry....more
5/5/2025
/ Banking Sector ,
Cryptocurrency ,
Digital Assets ,
FDIC ,
Federal Reserve ,
Financial Regulatory Reform ,
FinTech ,
FRB ,
OCC ,
Regulatory Oversight ,
Regulatory Reform
In light of ongoing litigation and the Trump administration’s new policy approach, federal banking agencies intend to rescind the 2023 CRA final rule and revert to pre-2023 standards....more
4/8/2025
/ Banking Regulators ,
Banking Sector ,
Biden Administration ,
Community Reinvestment Act ,
FDIC ,
Federal Reserve ,
Final Rules ,
Judicial Authority ,
OCC ,
Regulatory Reform ,
Trump Administration
New FDIC guidance permits crypto activities by supervised institutions without prior approval, emphasizing risk management and compliance with applicable laws and regulations....more
In a break from restrictive Biden-era policies, OCC-supervised banks may now engage in crypto without supervisory nonobjection, potentially opening new avenues for innovation....more
Stablecoin regulation is a top priority for lawmakers, and three recent proposals reflect differing perspectives on how to achieve regulatory clarity while balancing safety and innovation....more
A Republican Congress and the incoming Trump administration may employ the CRA to quickly overturn recent rules that faced heavy criticism from the financial services industry....more
1/22/2025
/ Congressional Review Act ,
Consumer Financial Protection Bureau (CFPB) ,
Deregulation ,
Digital Assets ,
FDIC ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
IRS ,
OCC ,
Open Banking ,
Trump Administration
“Fair access” banking laws, at the epicenter of the debates between ESG and “anti-woke” regulation and federal/state preemption, may see a resurgence under the incoming administration.
In recent years, the landscape of...more
1/8/2025
/ Banking Sector ,
Biden Administration ,
Compliance ,
Consumer Protection Laws ,
Dodd-Frank ,
Environmental Social & Governance (ESG) ,
Fair Access to Credit ,
Fair Lending ,
Financial Institutions ,
Financial Regulatory Reform ,
OCC ,
Preemption ,
Regulatory Agenda ,
Regulatory Freeze ,
State and Local Government ,
Trump Administration
In February 2024, we issued a report on the public comments received on the proposal of the Board of Governors of the Federal Reserve System (Federal Reserve), the Office of the Comptroller of the Currency (OCC), and the...more
11/19/2024
/ Board of Governors ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Agencies ,
Global Systemically Important Banks (G-SIBs) ,
Market Risk Capital Rule ,
Minorities ,
OCC ,
Public Comment ,
Rulemaking Process ,
Securitization ,
Stress Tests
Regulators seek to provide clarity and transparency on the bank merger review process, but changes may increase application complexity and unpredictability.
Consistent with ongoing initiatives to strengthen US antitrust...more
The proposal would establish stricter oversight of certain transactions and responds to concerns that large asset managers may be exerting influence on FDIC-supervised institutions.
On July 30, 2024, the Board of...more
8/9/2024
/ Acquisitions ,
Banking Sector ,
Banks ,
Change in Control ,
Consumer Financial Protection Bureau (CFPB) ,
Depository Institutions ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
NPRM ,
OCC ,
Proposed Amendments ,
Publicly-Traded Companies
OCC-supervised institutions with $100 billion or more in average total consolidated assets must be adequately prepared to mitigate severe financial and non-financial risks. ...more
The proposal seeks to make executive compensation arrangements more sensitive to risk and would require complex risk management programs to ensure compliance....more
5/30/2024
/ Dodd-Frank ,
Executive Compensation ,
FDIC ,
FHFA ,
Financial Services Industry ,
Incentive Compensation ,
NCUA ,
NPRM ,
OCC ,
Proposed Rules ,
Risk Management
As federal regulation remains patchy, firms may want to consider a New York state charter as a potential avenue to expand digital asset offerings in a compliant manner.
On March 22, 2024, WisdomTree, Inc., a global asset...more
4/5/2024
/ Custody ,
Digital Assets ,
Exemptions ,
Fiduciary ,
FinTech ,
Investment Management ,
Investment Trust Companies ,
Market Participants ,
Money Transmitter ,
NYDFS ,
OCC ,
Stablecoins ,
State Charters ,
Subsidiaries
Banking agencies are alleged to have exceeded their congressional authorization, with potentially adverse consequences on banks and consumers.
On February 5, 2024, several banking trade groups[1] (the Plaintiffs) sued...more
The OCC outlines safety and soundness principles and appropriate risk management processes for its regulated institutions that engage in BNPL lending.
On December 6, 2023, the Office of the Comptroller of the Currency...more
The OCC outlines safety and soundness principles and appropriate risk management processes for its regulated institutions that engage in venture lending.
On November 1, 2023, the Office of the Comptroller of the Currency...more
11/29/2023
/ Banking Crisis ,
Banking Sector ,
Commercial Loans ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Lenders ,
New Guidance ,
OCC ,
Risk Management ,
State Charters
Guidance for the largest US financial institutions is intended to promote climate risk management consistent with general safety and soundness practices.
On October 30, 2023, the three US federal bank regulatory agencies...more
11/8/2023
/ Banking Sector ,
Biden Administration ,
Climate Change ,
Corporate Governance ,
Disclosure Requirements ,
Executive Orders ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
New Guidance ,
OCC ,
Policies and Procedures ,
Risk Assessment ,
Risk Management ,
Strategic Planning
The guidance outlines principles and key considerations for banking organizations as they navigate risks associated with third parties, including fintechs.
On June 6, 2023, the Federal Deposit Insurance Corporation...more
6/23/2023
/ Banking Sector ,
FDIC ,
Financial Institutions ,
FinTech ,
FRB ,
Interagency Guidance ,
OCC ,
Risk Management ,
Third-Party ,
Third-Party Relationships ,
Third-Party Risk
President Biden is calling for tougher standards and supervision for large regional banks in the wake of recent instability in the US banking sector.
On March 30, 2023, the White House issued a Fact Sheet calling on the...more
4/4/2023
/ Banks ,
Biden Administration ,
Deregulation ,
Dodd-Frank ,
FDIC ,
Financial Institutions ,
FRB ,
OCC ,
Regulatory Agenda ,
Relief Measures ,
Trump Administration
The Acting Comptroller of the OCC discussed the limits of large bank manageability and the steps that regulators can take to address the risks posed by size and complexity.
On January 17, 2023, Acting Comptroller of the...more
Banking organizations should ensure appropriate risk management, but regulators are skeptical of certain crypto activities as principal.
On January 3, 2023, the Board of Governors of the Federal Reserve System (Federal...more
1/12/2023
/ Banking Regulators ,
Banking Sector ,
Cryptoassets ,
Cryptocurrency ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Joint Statements ,
OCC ,
Risk Assessment ,
Risk Management