The Board of Governors of the Federal Reserve (the "Federal Reserve") has over several decades defined when an activity engaged in by foreign banks subject to the Bank Holding Company Act of 1956 (the "BHCA"), which are thus...more
As with any new phenomenon, the rise of digital assets has created a new lexicon. "Blockchain," "tokens," and "coins" are now household vocabulary. Central to the discussion are a set of assets generally classified as...more
On November 23, 2021, the Chief Counsel and Senior Deputy Comptroller Benjamin W. McDonough of the Office of the Comptroller of the Currency (the "OCC") issued OCC Interpretive Letter 1179 (dated November 18, 2021) ("IL...more
There has been recent speculation that banks are about to enter the cryptocurrency markets. This makes a lot of commercial sense: There clearly is customer demand for banks to offer services similar to those they offer for...more
6/7/2021
/ Bank Holding Company Act ,
Banking Sector ,
Bitcoin ,
Blockchain ,
CFTC ,
Commodity Exchange Act (CEA) ,
Cryptocurrency ,
Digital Assets ,
Distributed Ledger Technology (DLT) ,
Federal Reserve ,
Volcker Rule