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Virtual "Currencies": Not actual currencies

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

UnSound: OCC IL 1179 and Its Backwards Creation of New Law

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

Complementary: Bitcoin trading requires complementary to a financial activity authority under the Bank Holding Company Act

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

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