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OCC Preempts Illinois Interchange Fee Law

The OCC issued two interim final actions preempting the Illinois Interchange Fee Prohibition Act, causing the Seventh Circuit to vacate and remand related proceedings to the district court....more

US Banking Regulators Finalize Rule Eliminating Use of Reputation Risk

The OCC and FDIC’s jointly codified rule prohibits regulators from using reputational risk as a basis for criticisms, adverse actions, or pressure on banks’ customer relationships....more

OCC Issues Proposal to Implement the GENIUS Act

The Proposal would establish many requirements for OCC supervised entities, including reserves, capital standards, redemption timelines, and the extent of OCC supervisory authority....more

OCC Finalizes Rule on National Trust Bank Activities

The Rule provides critical regulatory clarity for entities seeking national trust bank charters to engage in digital asset activities....more

Federal Court Partially Upholds Illinois Law Limiting Interchange Fees

The decision clears a legal path for state-level regulation of credit and debit card swipe fees (while striking down data usage restrictions), setting the stage for a high-stakes appeal....more

10 Key Focus Areas for US Bank Regulators in 2026

In this publication, we explore 10 key focus areas for US bank regulators in the year ahead. Building on a fast start in 2025, 2026 is shaping up to be an extraordinarily active year, as US bank regulators continue down...more

OCC Proposes Regulation to Clarify Permissible Activities for Trust Banks

The Proposal addresses recent comments about the scope of permissible activities for national trust banks, as applications to charter new banks continue to be filed....more

FDIC Issues Proposal to Implement GENIUS Act

The proposal outlines the application process and the factors that the FDIC will consider in granting approval for an entity to issue payment stablecoins....more

OCC Continues to Move Digital Assets Into the Banking System

The OCC affirmed that certain cryptoasset activities are part of, or incidental to, the business of banking and conditionally approved five national trust bank charters for digital asset entities....more

OCC and FDIC Withdraw From Leveraged Lending Guidance

Banks subject to the Agencies’ jurisdiction will now be expected to manage leveraged lending using general risk management principles for safe and sound lending....more

The Road Ahead for Fintech Rulemaking

As the fintech landscape evolves, federal banking regulators are taking decisive steps to integrate stablecoins and payments innovations into the traditional banking system....more

Federal Reserve Board Finalizes Revisions to Its Supervisory Rating Framework

The FRB will focus on overall safety and soundness rather than single deficiencies, allowing more large financial institutions to qualify as “well managed.”...more

OCC Takes Action to Curtail Debanking

OCC Bulletins 2025-22 and 2025-23 clarify the agency’s approach to evaluating banks’ compliance with fair banking practices and protecting customers’ financial records....more

Treasury Invites Public Input on GENIUS Act Implementation

The request for comment aims to help Treasury devise clear guidelines for stablecoin issuers, promote international coordination, and protect consumers from potential risks....more

FDIC Issues Proposal on Signage and Advertising Requirements

The FDIC seeks to avoid overburdening financial services providers with regulations regarding its logo after assessing market feedback and implementation issues....more

President Trump Issues Executive Order on Fair Banking

Regulators are directed to avoid reputation risk, identify banks that have engaged in unlawful debanking, and take appropriate remedial actions. ...more

Presidential Working Group Issues Report and Recommendations on Digital Asset Markets

The report reflects collaboration across federal agencies and aims to establish US leadership in digital assets through forward-thinking policy and a clear regulatory framework....more

The GENIUS Act of 2025 Stablecoin Legislation Adopted in the US

On July 18, 2025, President Trump signed into law the Guiding and Establishing National Innovation for US Stablecoins Act (the GENIUS Act), legislation that establishes a regulatory framework for payment stablecoins. ...more

Banking Agencies Issue Joint Statement on Risk-Management Considerations for Cryptoasset Safekeeping

Banking organizations safekeeping digital assets for customers must do so in a safe and sound manner and in compliance with applicable laws and regulations....more

OCC Bank Merger Rule Rescinded in Latest Regulatory Reversal

The OCC is restoring its former practices and policies under the Bank Merger Act to reinstate expedited merger reviews and streamlined business combination applications....more

OCC Affirms Banks Can Engage in Crypto Custody and Execution Activities

The federal banking agencies continue to open the channels for regulated entities to engage in digital asset activities. On May 7, 2025, the Office of the Comptroller of the Currency (OCC) published Interpretive Letter...more

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