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Regulation in Flux, March 2025 - OCC Gives Green Light to National Bank Fintech Business Model

On March 17th, the Office of the Comptroller of the Currency (“OCC”) conditionally approved the application for the newly renamed SmartBiz Bank N.A. (“SmartBiz Bank”) to change its business model in support of its fintech...more

President Trump Sends Three Financial Regulatory Nominations to the Senate

On February 12th, the White House announced numerous nominations to be sent to the Senate. The large list of nominations included three nominations for financial regulators. President Trump is nominating, Jonathan Gould to be...more

FDIC Acting Chair Hill Orders Release of Trove of Crypto-Related Documents

On February 5, the Federal Deposit Insurance Corporation (“FDIC”) released 175 documents related to supervision of banks it oversees that either engaged in or sought to engage in crypto-related activities.  Acting Chairman...more

Banking Agencies Issue Joint Statement on Crypto-related Liquidity Risks

Earlier yesterday, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”) issued a “Joint Statement on Liquidity Risks to Banking Organizations...more

FRB Issues Policy Statement on Permissible Activities of State Member Banks While Denying Uninsured Crypto-focused Bank’s...

The Federal Reserve Board (“FRB” or “Board”) issued two seemingly related press releases late last week. The first announced the denial of the Federal Reserve membership application by Custodia Bank, a Wyoming special purpose...more

Looking Back on 2022 and Looking Ahead to 2023 – U.S. Prudential Bank Regulation

As we are coming to a close on 2022, we’re taking a look back at some of the important developments of 2022 and what lies ahead for 2023. Looking Back at 2022 - As past readers may have seen me say before, there’s a...more

FDIC Acting Chair Talks Prudential Regulation of Crypto-Assets

Last week, Martin Gruenberg, Acting Chair of the Federal Deposit Insurance Corporation (“FDIC”), gave remarks at the Brookings Institution on the Prudential Regulation of Crypto-Assets....more

FDIC Makes Clear That It Does Not Insure Crypto Exchanges

Last week, the Federal Deposit Insurance Corporation (“FDIC”) was part of two releases clarifying that only insured banks and thrifts enjoy FDIC insurance, notwithstanding what some non-banks may say in their marketing...more

Regulators in Multiple Jurisdictions Call for More Oversight of Crypto-Assets and Stablecoins

The last week has seen a number of announcements or statements from financial regulators calling for more oversight of crypto-assets, particularly stablecoins. Federal Reserve Vice Chair Lael Brainard gave a speech,...more

Acting Comptroller Hsu Brings Crypto-Skepticism to Blockchain Summit

This week, Acting Comptroller of the Currency Michael Hsu gave remarks to the DC Blockchain Summit titled “Crypto: A Call to Reset and Recalibrate.” By speaking at the Blockchain Summit, Mr. Hsu may have gone into the...more

FDIC Weighs In on Crypto Activities

Last week, the FDIC issued a Financial Institution Letter (“FIL”) related to crypto activities, following in some ways in the footsteps of the OCC in requiring notice to the regulator before engaging in crypto-related...more

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