Promissory Notes - Banking & Finance Insights, Issue 4

Welcome to our fourth issue of Promissory Notes -- our e-newsletter focused on banking and finance insights. We hope you are enjoying our monthly publication.

New OCC Chief Signals Greater Caution on Crypto

"'We created an Office of Innovation, updated the framework for chartering national banks and trust companies, and interpreted crypto custody services as part of the business of banking.'"

Why this is important: With cryptocurrency becoming increasingly popular and a new acting comptroller, Michael Hsu, the Office of the Comptroller of Currency (“OCC”) is seeking to review crypto-related guidance issued over the past year. While testifying before the House Committee on Financial Services, Hsu stated he was concerned the guidance had not been “done in full coordination with all stakeholders” and they do not “appear to have been part of a broader strategy related to the regulatory perimeter.” Further, Hsu stated he is not ruling out granting charters to fintech companies but that the OCC, in conjunction with the FDIC, Federal Reserve, and the states, must figure out how they fit within the banking system. What they decide on likely will have a lasting impact on the future of fintech and crypto-related companies.

Please see full Newsletter below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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