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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

FDIC Conducts Regulatory Review and Purge

Under its new acting chairman appointed by President Trump, the FDIC charges ahead with its new agenda by rolling back key Biden-era regulatory efforts. On March 3, 2025, the Federal Deposit Insurance Corporation (FDIC)...more

FDIC Acting Chairman Charts a Fresh Path Forward for the Agency

The FDIC seeks to stick to its statutory mandate while reducing impediments to fintech, innovation, mergers, bank formation, and efficient supervision....more

The Story Of 2024's Biggest Bank Regs, And Their Fate In 2025

In 2024, the U.S. federal bank regulators were extremely active, with initiatives ranging from antitrust and capital to proposals regarding controlling shareholders and incentive-based compensation. Climate issues and...more

Barr Speech on the Basel Endgame - A Snapshot: Many Comments Unaddressed and Significant Concerns Remain

On September 10, Federal Reserve Vice Chair for Supervision Barr gave a speech (the Barr Speech) in which he outlined the principal changes to the federal banking agencies' 2023 proposal to implement the Basel Endgame (the...more

FDIC, OCC Finalize Policy on Bank Merger Transactions

Regulators seek to provide clarity and transparency on the bank merger review process, but changes may increase application complexity and unpredictability. Consistent with ongoing initiatives to strengthen US antitrust...more

FDIC Proposes Amendments to Its Change in Bank Control Act Regulations

The proposal would establish stricter oversight of certain transactions and responds to concerns that large asset managers may be exerting influence on FDIC-supervised institutions. On July 30, 2024, the Board of...more

Agencies Issue Joint Proposal to Amend Bank Secrecy Act Compliance Programs for Banks

On July 19, 2024, 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), and the National Credit Union Administration...more

OCC Proposes Updates to Large Bank Recovery Planning Guidelines

OCC-supervised institutions with $100 billion or more in average total consolidated assets must be adequately prepared to mitigate severe financial and non-financial risks. ...more

FDIC Expands Resolution Plan Requirements for Banks with Assets of $50B or More

Insured depository institutions with $50 billion to less than $100 billion in average total assets are subject to new resolution reporting standards, with enhanced reporting for those with average total assets of $100 billion...more

FDIC Proposes Revisions to Policy on Bank Merger Transactions

The Proposal clarifies the FDIC’s bank merger approval process but may prove challenging for new large bank consolidations with the FDIC as the primary regulator. On March 21, 2024, the Board of Directors of the Federal...more

FRB Clarifies Supervision of Digital Assets and Bank-Fintech Partnerships

A new program addresses innovative banking activities such as bank-fintech partnerships and digital assets while reinforcing guardrails around stablecoin activity. On August 8, 2023, the Board of Governors of the Federal...more

FDIC Vice Chairman Cautions Against New Regulation as a Response to Recent Bank Failures

In contrast with the White House’s position, the Vice Chairman denied that loosened Dodd-Frank rules contributed to the recent bank failures. On April 12, 2023, Federal Deposit Insurance Corporation (FDIC) Vice Chairman...more

White House Recommends Stricter Regulations for Large Regional Banks

President Biden is calling for tougher standards and supervision for large regional banks in the wake of recent instability in the US banking sector. On March 30, 2023, the White House issued a Fact Sheet calling on the...more

Federal Reserve Establishes Bank Term Funding Program to Stabilize Financial System

The decisive action will mitigate emerging liquidity and solvency risks, contain pressure on the banking system, and protect depositors. On March 12, 2023, the Board of Governors of the Federal Reserve System (Federal...more

Federal Reserve Narrows the Crypto Activities of Member Banks

Custodia Bank was denied Federal Reserve membership, while certain crypto principal activities are deemed presumptively not appropriate for member banks. On January 27, 2023, the Board of Governors of the Federal Reserve...more

New York Department of Financial Services Issues Crypto Custody Guidance

The Guidance clarifies the regulator’s expectations on safekeeping customer digital assets, and the disclosures that must accompany such arrangements. On January 23, 2023, the New York Department of Financial Services...more

Acting Comptroller Confronts “Too Big to Manage” Issue

The Acting Comptroller of the OCC discussed the limits of large bank manageability and the steps that regulators can take to address the risks posed by size and complexity. On January 17, 2023, Acting Comptroller of the...more

Two Proposed Volcker Rule Updates: “Banking Entity” Definition and Name-Sharing Restriction

The proposed modifications, if adopted, would amend the Volcker Rule in a manner consistent with the statutory amendments under the Economic Growth, Regulatory Relief, and Consumer Protection Act. The Economic Growth,...more

Federal Reserve Board Grants One-year Extension on Volcker Rule Conformance for Certain Covered Funds

The Federal Reserve today extended the Volcker Rule conformance period for legacy covered funds from July 21, 2015 to July 21, 2016, and also granted a further one year extension until July 21, 2017. At 3 pm today...more

Volcker Rule: An Initial Look at Significant Changes

On December 10, 2013 the US federal banking agencies, along with the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) (collectively, the Agencies), adopted the ...more

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