On March 7, the OCC issued Interpretive Letter 1183 and an accompanying statement affirming prior guidance regarding whether national banks and federal savings associations may engage in cryptocurrency-related activities,...more
On March 7, the Office of the Comptroller of the Currency (OCC) issued a significant update regarding the involvement of national banks and federal savings associations in cryptocurrency activities. Interpretive Letter 1183...more
The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a July 16th Interpretive Letter the application of the federal Hazardous Materials Regulations (“HMR”) applicable to: …the size of a...more
The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a November 22, 2022, Interpretive Letter the application of the Hazardous Materials Regulations to hazardous materials training for a forklift...more
With the number of on-site inspections and citations declining during the 2020 pandemic, it appeared that the Occupational Safety and Health Administration began issuing more citations for recordkeeping-related...more
Can you say 0 to 60? Not cars, but pretty much everything to do with financial services. A new year, a new administration, and new challenges for providers. Prior CFPB Director Kraninger is long gone. Acting Director Uejio...more
The Situation: On January 4, 2021, the Office of the Comptroller of the Currency ("OCC") issued an Interpretive Letter permitting national banks and federal savings associations ("Banks") to participate in independent node...more
As part of the Office of the Comptroller of the Currency’s (OCC) declared effort to keep pace with a mounting demand for faster, cheaper, and more efficient payments, and the widespread adoption of new technologies, the...more
In this Issue. The Office of the Comptroller of the Currency (OCC) issued guidance on its authority to charter limited purpose trust companies, raising the possibility that a limited purpose national bank could be organized...more
In this Issue. The Securities and Exchange Commission (SEC) finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors, and published a risk...more
On January 4, 2021, the Office of the Comptroller of the Currency (OCC) issued the latest in a string of interpretative letters on permissible crypto-related activities of national banks and federal savings associations...more
The Chief Counsel of the Office of the Comptroller of the Currency has issued Interpretive Letter 1173, addressing national bank and federal savings association preemption of state law under the Dodd-Frank Act....more
In the News. Institutional Shareholder Services (ISS) published its proxy voting guidelines updates for 2021, which include new and updated voting recommendations on federal forum and exclusive forum provisions in companies’...more
The US OCC allows banks, with certain restrictions, to hold assets in reserve for stablecoin issuers. On September 21, 2020, the US Office of the Comptroller of the Currency (OCC) issued Interpretive Letter #1172 (the...more
In the News. The Board of Governors of the Federal Reserve System (Federal Reserve) proposed rules to modernize the regulations that implement the Community Reinvestment Act (CRA); the Conference of State Bank Supervisors...more
The OCC sees holding the cryptographic access keys to control and transfer cryptocurrency as an "electronic corollary" of banking's traditional safekeeping methods. On July 22, 2020, the Office of the Comptroller of the...more
Banking regulators took a significant step toward the mainstreaming of cryptocurrency recently when the Office of the Comptroller of the Currency (OCC) provided guidance about how a bank can provide custody services for...more
The OCC greenlights bank custody of cryptoassets, opening a significant door to mainstream adoption and innovation. On July 22, 2020, the US Office of the Comptroller of the Currency (OCC) issued Interpretive Letter #1170...more
The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a January 2nd interpretive letter a question regarding the application of the Hazardous Materials Regulations (“HMR”) to...more
The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a January 17th letter a question regarding the applicability of the Hazardous Materials Regulations (“HMR”) applicable to the...more
The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a December 6th letter the Hazardous Materials Regulation (“HMR”) applicable to the marking requirements for a Department of...more
The United States Department of Transportation Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a November 26th letter a question addressing the Hazardous Materials Regulations (“HMR”) pressure...more
The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in an October 15th interpretive letter clarification of the Hazardous Material Regulation (“HMR”) pertaining to the classification of explosives. ...more
This newsletter discusses noteworthy updates, key regulatory decisions and upcoming compliance reminders. In this edition, we review: ...SEC Changes Approach to Shareholder Proposal No-Action Requests ...SEC Issues...more
The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a September 20th interpretive letter a request for clarification of the Hazardous Materials Regulations (“HMR”) applicable to...more