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Office of the Comptroller of the Currency Regulatory Requirements

Fenwick & West LLP

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

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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

Mayer Brown

OCC Reiterates Full Scope of Crypto Custody Authority of Banks It Regulates

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On May 7, 2025, the Office of the Comptroller of the Currency (“OCC”) issued Interpretative Letter 1184 (“IL 1184”) confirming that national banks and federal savings associations may provide cryptocurrency custody...more

DLA Piper

Blockchain and Digital Assets News and Trends – May 2025

DLA Piper on

This periodic bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets. While the use cases for blockchain...more

Orrick, Herrington & Sutcliffe LLP

Acting Comptroller discusses importance of financial inclusion

On May 8, Acting Comptroller of the Currency Rodney E. Hood spoke on his four priority areas: financial inclusion, reducing regulatory burdens, bank-fintech partnerships, and digital assets. He emphasized that financial...more

Orrick, Herrington & Sutcliffe LLP

OCC clarifies crypto-asset activities in interpretive letter

On May 7, the OCC clarified permissible activities for national banks and federal savings associations regarding crypto-asset custody and execution services by publishing Interpretive Letter 1184. This letter confirmed...more

Goodwin

Regulatory Process for Forming or Acquiring a Depository Institution

Goodwin on

This third installment in our series of insights on bank charter considerations describes the process for seeking regulatory approval to form or acquire a bank....more

Latham & Watkins LLP

OCC Affirms Banks Can Engage in Crypto Custody and Execution Activities

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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

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

K&L Gates LLP

Federal Banking Regulators Adopt a Permissive Stance on Cryptocurrency

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The federal banking regulators have each recently adopted a more permissive approach to the regulation of cryptocurrency activities within the banking sector. The Office of the Comptroller of the Currency (OCC), the Federal...more

Orrick, Herrington & Sutcliffe LLP

OCC’s Hood emphasizes responsible AI use for financial inclusion

On April 29, Rodney E. Hood, Acting Comptroller of the Currency, delivered a speech for the National Fair Housing Alliance’s Responsible AI Symposium. In his remarks, Hood emphasized the importance of financial inclusion and...more

Nutter McClennen & Fish LLP

Nutter Bank Report: April 2025

The Federal Reserve has announced multiple decisions to rescind existing requirements for crypto-asset activities. The April 24 announcement included the rescission of a 2022 supervisory letter that required state member...more

Paul Hastings LLP

Support for Stablecoin Legislation and Leadership Confirmations

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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

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

Orrick, Herrington & Sutcliffe LLP

OCC provides an update on its security breach given institutional risk

On April 14, the OCC released a letter providing more details on the recent security breach involving its email systems. The breach — identified as a major incident under the Federal Information Security Modernization Act...more

Paul Hastings LLP

Daily Financial Regulation Update -- Monday, April 21, 2025

Paul Hastings LLP on

April 18, 2025 - The Federal Reserve and the Office of the Comptroller of the Currency have conditionally approved the merger of Discover Bank, Greenwood, Delaware, into Capital One, National Association, McLean, Virginia....more

Paul Hastings LLP

Daily Financial Regulation Update -- Thursday, April 17, 2025

Paul Hastings LLP on

April 16, 2025 - The U.S. Department of the Treasury released Treasury International Capital (TIC) data for February 2025. The next release, which will report on data for March 2025, is scheduled for May 16, 2025....more

Paul Hastings LLP

Daily Financial Regulation Update -- Wednesday, April 16, 2025

Paul Hastings LLP on

April 15, 2025 - The Federal Reserve Board, Federal Deposit Insurance Corporation, National Credit Union Administration and Office of the Comptroller of the Currency temporarily paused certain appraisal requirements for...more

Alston & Bird

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

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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

Troutman Pepper Locke

OCC Notifies Congress of Major Email System Security Breach

Troutman Pepper Locke on

On April 8, the Office of the Comptroller of the Currency (OCC) officially notified Congress of a significant information security incident involving its email system. This notification, mandated by the Federal Information...more

Mayer Brown

FDIC Streamlines Process for Cryptocurrency Activities by Banks It Regulates and Speculates on Additional Permissible Activities

Mayer Brown on

On March 28, 2025, the Federal Deposit Insurance Corporation (FDIC) issued guidance on state nonmember bank and state savings association participation in certain cryptocurrency activities (“FIL-7-2025”). ...more

Sheppard Mullin Richter & Hampton LLP

Federal Regulators Signal Reversal on 2023 CRA Modernization Rule

On March 28, the Federal Reserve, FDIC, and OCC jointly announced plans to rescind 2023 revisions to the Community Reinvestment Act (CRA) regulations. The agencies stated they would return to the previous regulatory framework...more

Orrick, Herrington & Sutcliffe LLP

North Dakota amends regulations on appraisal management companies

On March 26, North Dakota enacted HB 1080 (the “Act”) which amends regulations pertaining to appraisal management companies. The Act generally specifies owner requirements, prohibiting registration for companies owned by...more

Jones Day

OCC Ends Climate Risk Guidance for Large Banks

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In a recent shift, the Office of the Comptroller of the Currency (OCC) has officially ended its climate risk guidance for large U.S. banks. The 2021 guidance called on major banks to incorporate climate-related risks into...more

Jones Day

FDIC Rescinds Prior Notification Requirement for Banks' Permissible Crypto Activities

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The FDIC has rescinded an earlier Financial Institution Letter establishing a prior notification requirement for FDIC-supervised institutions that wish to engage in specified crypto-related activities and has clarified that...more

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