News & Analysis as of

Office of the Comptroller of the Currency Regulatory Oversight

Orrick, Herrington & Sutcliffe LLP

GAO pens letter to OCC’s Hood on outstanding recommendations

On May 15, the GAO penned a letter to the Acting Comptroller of the Currency, Rodney E. Hood, highlighting areas it believes warrant the OCC’s focus. First, the GAO recommended that the OCC establish policies and procedures...more

Fenwick & West LLP

Bank-Fintech Partnerships Under Scrutiny: What Fintechs Need to Know About AML Expectations

Fenwick & West LLP on

Bank-fintech partnerships have transformed the financial services landscape, creating new opportunities and challenges for traditional banking institutions and innovative technology companies alike. In a typical arrangement,...more

Orrick, Herrington & Sutcliffe LLP

GAO Report Reveals How Financial Institutions (And Their Regulators) Are Using AI

Curious about how financial institutions, their service providers, and their federal regulators are using and overseeing machine learning and other AI tools? A new GAO report published on May 19th (the “Report”) provides a...more

Orrick, Herrington & Sutcliffe LLP

OCC releases May 2025 enforcement actions

On May 15, the OCC announced enforcement actions against two banks and three institution-affiliated parties. The OCC issued cease and desist orders to banks in Miami, as well as Beverly Hills, California, respectively, for...more

Patomak Global Partners

Fed Withdrawal of Guidance Marks Milestone for Banks’ Future Crypto Activity

The federal banking agencies have withdrawn previously issued guidance related to banks’ crypto activities, marking a shift in regulatory posture toward digital asset engagement. On April 25, the Federal Reserve Board...more

Sheppard Mullin Richter & Hampton LLP

OCC Confirms Banks Authority to Offer Crypto Custody and Execution Services

On May 7, the OCC issued Interpretive Letter 1184, reaffirming that national banks and federal savings associations may provide cryptocurrency custody and execution services, including through sub-custodians. The OCC...more

Orrick, Herrington & Sutcliffe LLP

OCC releases April CRA performance evaluations

On May 1, the OCC released its CRA performance evaluations that became public during the month of April. The OCC evaluated 26 entities, including national banks, federal savings associations, and insured federal branches of...more

Orrick, Herrington & Sutcliffe LLP

OCC requests information on banks’ digitalization efforts

On May 5, the OCC released a request for information (RFI) seeking public comment on community banks’ efforts towards digitalization. The OCC stated this RFI will enhance its supervisory activities. The OCC aims to understand...more

McGuireWoods LLP

Banks May Provide Cryptocurrency Transaction and Custody Services, but OCC Has Yet to Provide Clear Compliance Requirements

McGuireWoods LLP on

On May 7, 2025, the Office of the Comptroller of the Currency (“OCC”) issued a follow up to its July 2020 Interpretative Letter 1170, which allowed national banks to provide cryptocurrency custody services to their customers....more

Sheppard Mullin Richter & Hampton LLP

OCC’s Hood Emphasized AI Oversight and Inclusion in Financial Services

On April 29, Acting Comptroller of the Currency Rodney Hood delivered pre-recorded remarks at the National Fair Housing Alliance’s Responsible AI Symposium.  In his speech, Hood reiterated the OCC’s commitment to deploying AI...more

Latham & Watkins LLP

FRB Rescinds Previous Guidance Regarding Crypto Activities in the Banking Sector

Latham & Watkins LLP on

FRB eases crypto restrictions on supervised entities in alignment with the new administration’s support for the digital asset industry....more

Orrick, Herrington & Sutcliffe LLP

Regulators withdraw crypto guidance, plan further clarity for banks

On April 24, the FDIC and the Fed announced they have retracted two joint statements concerning banking organizations’ activities related to crypto-assets. According to the agencies, this move aims to clarify that banking...more

Orrick, Herrington & Sutcliffe LLP

OCC releases April 2025 enforcement actions

On April 17, the OCC announced enforcement actions against three institution-affiliated parties, alleging in the first instance fund misappropriation, in the second Paycheck Protection Program fraud, and in the last...more

Paul Hastings LLP

Support for Stablecoin Legislation and Leadership Confirmations

Paul Hastings LLP on

While the House and Senate were out of session for the last two weeks, federal financial regulators and legislators took a wide range of actions impacting the future of digital asset policy. Senate Banking Chair Tim Scott...more

Ballard Spahr LLP

OCC, FDIC eliminating ‘reputational risk’ from supervision, examinations

Ballard Spahr LLP on

The OCC has removed “reputational risk” from its handbooks and guidance and the FDIC is moving to do the same. ...more

Stinson LLP

CFPB and OCC Signal Strategic Shifts in Supervision and Enforcement

Stinson LLP on

In April 2025, both the Consumer Financial Protection Bureau (CFPB) and the Office of the Comptroller of the Currency (OCC) announced significant changes to their supervisory and enforcement approaches, signaling a shift in...more

Alston & Bird

Federal Banking Agencies Announce Intent to Rescind 2023 Community Reinvestment Act Final Rule and Return to Prior Framework

Alston & Bird on

What Happened? The Federal Deposit Insurance Corporation (“FDIC”), Board of Governors of the Federal Reserve System (“Federal Reserve”) and the Office of the Comptroller of the Currency (“OCC”), (collectively, “federal...more

King & Spalding

OCC Clarifies Crypto-Asset Guidance

King & Spalding on

The Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) have both recently taken actions and issued statements that indicate a more permissive bank regulatory approach to...more

Mayer Brown

OCC Withdraws Climate Risk Management Principles

Mayer Brown on

On March 31, 2025, the Office of the Comptroller of the Currency withdrew its participation in the interagency principles for climate-related financial risk management for large financial institutions (the “Climate...more

Troutman Pepper Locke

Federal Banking Agencies Announce Intent to Rescind 2023 Community Reinvestment Act Final Rule

Troutman Pepper Locke on

On March 28, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (together, the federal banking agencies) announced their intent to rescind the...more

Katten Muchin Rosenman LLP

Banking Agencies Begin Publishing Updated Crypto Guidance

On March 28, the Federal Deposit Insurance Corporation (FDIC) rescinded Biden administration guidance related to state-chartered banks' participation in "crypto-related activities" and published a new interpretation of the...more

Troutman Pepper Locke

FDIC Turns a New Page on Banks’ Engagement in Crypto-Related Activities

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Last Friday, the Federal Deposit Insurance Corporation (FDIC) announced the rescission of Financial Institution Letter (FIL-16-2022) and issued new guidance clarifying the process for FDIC-supervised institutions to engage in...more

Stinson LLP

OCC Charts a New Path for FinTech Banking

Stinson LLP on

On March 17, the Office of the Comptroller of the Currency (OCC) announced that the agency granted conditional approval for a leading FinTech company to indirectly acquire a nationally chartered bank, enabling the FinTech...more

Brownstein Hyatt Farber Schreck

Regulating Digital Dollars: How Federal Bills Stack Up

In November of 2021, the President’s Working Group on Financial Markets, joined by the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC), issued a report formally...more

Troutman Pepper Locke

OCC Ceases Examinations for Reputation Risk Following Legislative Push

Troutman Pepper Locke on

On March 20, the Office of the Comptroller of the Currency (OCC) announced that it will no longer examine its regulated institutions for reputation risk. According to the OCC’s “Categories of Risk,” reputation risk is the...more

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