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
Following ongoing efforts to promote the expansiveness of the national bank charter, on July 22, 2020, the Office of the Comptroller of the Currency (OCC) issued an interpretive letter confirming the authority of a national...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 OCC released an interpretive letter (“Letter #1142”) in which it concluded that a national bank’s proposal to arrange for third-party repair and maintenance service providers to service on-lease railcars and act as an...more