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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

FDIC Rescinds Prior Notification Requirement for Banks' Permissible Crypto Activities

The FDIC has rescinded an earlier Financial Institution Letter establishing a prior notification requirement for FDIC-supervised institutions that wish to engage in specified crypto-related activities and has clarified that...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

OCC Proposal and Policy Statement on Bank Mergers Could Freeze the Banking Industry in Place

The Situation: On January 29, 2024, the Office of the Comptroller of the Currency ("OCC") requested comment on a proposed rule updating its bank merger rules and incorporating a policy statement (the "Proposal") on agency...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

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

Fed Policy Statement Adds Hurdles to Digital Asset Activities and Innovation by State Banks

In Short - The Situation: The Federal Reserve Board ("Board") has issued a new policy statement ("Policy Statement") imposing limits, including Board approval requirements, on digital asset activities and other novel...more

Bank Regulators Issue Joint Statement on Safety and Soundness of Crypto Activities

In Short - The Situation: Since clarifying the legal permissibility of certain crypto activities in 2020 and early 2021, the Federal banking agencies have begun to tighten regulatory scrutiny of such activities, warning...more

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