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Federal Reserve Withdraws Crypto-Related Guidance Including Notification Requirements for Banking Organizations

The Federal Reserve Board ("Board") softened its stance on regulation of crypto activity by banking organizations by rescinding supervisory letters that created hurdles for crypto-asset activities and by joining the Office of...more

OCC Eases Some Restrictions on Bank Digital Asset Activities

In recent years, U.S. federal bank regulators significantly limited banks' authority to engage in crypto-asset activities, including participating in public blockchains, owning digital assets as principal, and even providing...more

Stablecoin Legislation: A Stroke of GENIUS?

President Trump's recent executive order "Strengthening American Leadership in Digital Financial Technology" promoted the development of dollar-backed stablecoins as official U.S. policy. To facilitate this policy, Congress...more

Final Climate Risk Guidance Ensures Supervisory Focus from Banking Agencies in 2024

The Situation: In October 2023, the Office of the Comptroller of the Currency ("OCC"), Federal Reserve System, and Federal Deposit Insurance Corporation ("FDIC," and the three agencies collectively, "Agencies") finalized...more

What About the Kitchen Sink? FSOC Plans Even More in 2024

In Short - The Situation: Over the course of 2023, the Financial Stability Oversight Council ("FSOC") took steps that increase the risk of nonbank financial companies and financial activities being designated as...more

Federal Banking Agencies Propose Long-Term Debt Requirements for Large Banks

In Short: The Situation: The Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (collectively, the "Agencies") have proposed rules...more

U.S. Federal Reserve Announces Climate Scenario Analysis Program

On September 29, 2022, the Board of Governors of the Federal Reserve System ("Fed") announced that six of the largest U.S. banks will participate in a first-of-its-kind climate scenario analysis program. The Fed will provide...more

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