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Key House Committee Chairs Release Draft Bill on Digital Asset Market Structure: Bill Would Establish CFTC/SEC Regulatory...

On May 5, 2025, the Republican committee chairs in the US House of Representatives with jurisdiction over digital asset legislation released a digital asset market structure discussion draft bill (the “Discussion Draft”). The...more

OCC Reiterates Full Scope of Crypto Custody Authority of Banks It Regulates

On May 7, 2025, the Office of the Comptroller of the Currency (“OCC”) issued Interpretative Letter 1184 (“IL 1184”) confirming that national banks and federal savings associations may provide cryptocurrency custody...more

OCC Withdraws Climate Risk Management Principles

On March 31, 2025, the Office of the Comptroller of the Currency withdrew its participation in the interagency principles for climate-related financial risk management for large financial institutions (the “Climate...more

Credibly Challenged Podcast: Interview With Mark Quandahl, Former Director of the Nebraska Department of Banking and Finance

Joe Castelluccio and Matt Bisanz interview Mark Quandahl, the former Director of the Nebraska Department of Banking and Finance. They discuss his role in the implementation of the Nebraska Financial Innovation Act, including...more

Congress Moves Forward on Stablecoin Legislation: The US Senate Banking Committee Approves the GENIUS Act

On March 13, 2025, the US Senate Banking Committee passed the Guiding and Establishing National Innovation for US Stablecoins Act of 2025 or “GENIUS Act,” out of committee by a vote of 18-6....more

President Trump’s First Week in Office is a Momentous One for Digital Assets: An Executive Order, Repeal of SAB 121 and a Clear...

WHAT THIS MEANS FOR BANKS, FINANCIAL SERVICES AND THE DIGITAL ASSETS SECTOR - Just four days after his inauguration, President Donald Trump has initiated a fundamental shift in federal policy on digital assets with a...more

Interview with Bryan Mulcahey, Managing Partner of FS Vector

Matt Bisanz interviews Bryan Mulcahey on his work with novel charters and the new Coalition for Financial Ecosystem Standards....more

CFPB Finalizes Long-Awaited Rule to Accelerate Open Banking Development; Immediately Sued

On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) finalized a rulemaking on Personal Financial Data Rights (the “Final Rule”). The Final Rule is intended to accelerate a shift towards open banking in the...more

FDIC Proposes New Recordkeeping Requirements for Custodial Accounts

On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed extensive new recordkeeping requirements and other compliance obligations (the “Proposal” ) for certain types of deposit accounts frequently...more

Interview with Jason Cave, Former Regulator Turned Industry Adviser

Matt Bisanz interviews former financial regulator Jason Cave to discuss developments in resolution and recovery planning, as well as trends in third-party risk management....more

Regulatory Redux: FDIC Proposes Brokered Deposit Revisions

On July 30, 2024, the FDIC proposed revisions to the restrictions on brokered deposits. The revisions would undo many of the key elements of the 2020 revisions, and would dramatically expand the number of deposit brokers and...more

US Banking Regulators Finalize Nonbank Lending Reporting Requirements

On May 22, 2024, the US federal banking regulators finalized a new set of reporting requirements for bank loans and commitments to fund finance facilities, private credit lenders, and other nonbank financial entities.This...more

Interview with Ethan Heisler of the Bank Treasury Newsletter

Matt Bisanz interviews Ethan Heisler, founder of the Bank Treasury Newsletter, on recent developments in bank funding risk....more

Interview with Isaac Boltansky from BTIG

Matt Bisanz interviews Isaac Boltansky, Director of Policy Research at BTIG, about the risks and regulatory trends for the rest of the year....more

What to Expect in Banking in 2024

The end of 2023 saw a barrage of major proposals and other actions by US banking regulators. Many of these are contentious issues that have divided regulators and generated significant public controversy. Final proposals of...more

Time Warp? Proposed Basel Endgame Reporting Requirements Released Before Final Rule

On January 26, 2024, the US federal banking regulators announced proposed reporting changes to implement the Basel III Endgame requirements. This may come as a surprise to the many banking organizations and others, who only...more

Comment Period for Basel III Endgame Proposal Closes

On January 16, 2024, the comment period closed for the US banking regulators’ Basel III Endgame proposal. Nearly 200 comment letters were submitted from the financial sector, commercial user, and the general public....more

Private Credit Reporting Requirements Proposed by US Banking Regulators

On December 27, 2023, the US federal banking regulators proposed a new set of reporting requirements for bank loans and commitments to private credit lenders and intermediaries....more

Cart Before Horse: Banking Regulators Extend Comment Period and Launch Data Collection for Basel Endgame

On October 20, 2023, the US federal banking regulators announced that they were extending the period for public comment to January 16, 2024 for both the (i) Basel Endgame proposal to significantly revise the risk-based...more

A Road Not Taken: Where the US Capital Proposal Differs From Basel

On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the riskbased regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”) and...more

Overhaul of Regulatory Capital Requirements Proposed by US Banking Regulators

On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the riskbased regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”), and...more

Biden Executive Order Calls for Regulatory Proposals on Digital Assets and Central Bank Digital Currency

On March 9, 2022, President Biden signed an executive order titled “Ensuring Responsible Development of Digital Assets” (the “Order”).1 The Order directs a broad range of federal agencies to recommend legislative and...more

Structured Finance Bulletin - Winter 2020

The implications of the 2020 election for structured finance are coming into focus. Informed by our discussions in Washington, we can anticipate the likely direction of federal policy over the next two years that will impact...more

US Agencies Proposed Revisions to Volcker Rule Covered Funds Provisions

On January 30, 2020, the Board of Governors of the Federal Reserve System (“FRB”), the Federal Deposit Insurance Corporation (“FDIC”), the Office of the Comptroller of the Currency (“OCC”), the Securities and Exchange...more

Potential Volcker Rule Changes Announced

On January 30, 2020, five federal financial regulatory agencies published the long awaited notice of proposed rulemaking (the “NPR”) to revise certain aspects of the Volcker Rule (Section 13 of the Bank Holding Company Act)...more

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