News & Analysis as of

Office of the Comptroller of the Currency Regulatory Requirements Regulatory Oversight

Orrick, Herrington & Sutcliffe LLP

OCC releases June 2025 enforcement actions

On June 18, the OCC announced enforcement actions against national banks, federal savings associations, and individuals currently or previously affiliated with supervised institutions. The OCC entered into three agreements...more

Sheppard Mullin Richter & Hampton LLP

OCC Enters Consent Orders Against New York-based Bank

On May 14, the OCC entered into a formal agreement with a New York-based bank after determining that the institution is in “troubled condition.” In its findings, the OCC cited alleged unsafe or unsound practices tied to the...more

Troutman Pepper Locke

Federal Banking Agencies Issue RFI on Payments and Check Fraud Mitigation Strategies

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On June 16, the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve Board, and the Office of the Comptroller of the Currency (OCC) issued a joint request for public comment on potential ways to address payments...more

Sheppard Mullin Richter & Hampton LLP

OCC Rejects Calls to Roll Back Preemption Rules

On June 9, Acting Comptroller of the Currency Rodney Hood issued a letter rejecting the Conference of State Bank Supervisors’ (CSBS) request that the OCC rescind its 2011 preemption regulations. The OCC ‘s letter signals...more

Orrick, Herrington & Sutcliffe LLP

OCC releases its May 2025 CRA performance evaluations

On June 2, the OCC released a list of CRA performance evaluations that became public during the month of May. The OCC evaluated 18 banking entities, including national banks, federal savings associations, and insured federal...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

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

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

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

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

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

Latham & Watkins LLP

OCC Affirms Regulated Entities Can Engage in Crypto and Stablecoin Activities

Latham & Watkins LLP on

In a break from restrictive Biden-era policies, OCC-supervised banks may now engage in crypto without supervisory nonobjection, potentially opening new avenues for innovation....more

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 57: Opening a Path for New Bank Formations

The Klaros Group’s Michele Alt joins Orrick partners Jerry Buckley, Caroline Stapleton and Walt Zalenski to explore actions needed to facilitate new bank formations, which have slowed to trickle in recent years. The...more

UB Greensfelder LLP

LPL AWC Proves, Once Again, That Big Firms Can Buy Their Way Out Of Trouble That Would Kill Small Firms

UB Greensfelder LLP on

LPL may be the biggest BD in the country, with 21,500 reps operating out of almost 13,000 branch offices. Heaven knows how much money it brings in every year, but, goodness, it must be a lot. And good thing, too, given how...more

Ballard Spahr LLP

Banking Regulators Ease SAR Reporting Requirements Applied to Hemp-Related Businesses

Ballard Spahr LLP on

On December 3, 2019, four federal agencies – the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (“FDIC”), the Financial Crimes Enforcement Network (“FinCEN”), and the Office of the...more

Ballard Spahr LLP

Fed reported to have reservations about fintech charter

Ballard Spahr LLP on

Last July, the OCC announced its decision to accept applications for special purpose national bank (SPNB) charters from fintech companies. ...more

Orrick, Herrington & Sutcliffe LLP

Federal Regulators Issue Key Guidance on Fintech Issues

On July 30, the U.S. Department of the Treasury ("Treasury") and the Office of the Comptroller of the Currency ("OCC") provided important guidance on a broad range of issues confronting the fintech industry. Treasury released...more

Herbert Smith Freehills Kramer

Financial Industry Awaits OCC Fintech Charter Decision

The regulatory landscape of the U.S. fintech industry could soon see a milestone development, as the Office of the Comptroller of the Currency (OCC) is expected to release its long-awaited position on a proposed charter for...more

Troutman Pepper Locke

Regulatory Uncertainty at Federal Level Continues for 'Bank Model' Lending Arrangements

Troutman Pepper Locke on

When differences emerge between the activities of state banks and national banks in the U.S. dual banking system, the root cause typically is a difference between state and federal law....more

Ballard Spahr LLP

Federal banking agencies issue policy statement on interagency notification of enforcement actions

Ballard Spahr LLP on

The federal banking agencies (the Federal Reserve Board, OCC, and FDIC (FBAs)), recently issued a “Policy Statement on Interagency Notification of Formal Enforcement Actions” that is intended “to promote notification of, and...more

Ballard Spahr LLP

Comptroller Otting to appear at House and Senate hearings next week

Ballard Spahr LLP on

Comptroller of the Currency Joseph Otting is scheduled to make two appearances before Congress next week. On Wednesday, June 13, 2018, he is scheduled to appear before the House Financial Services Committee at a hearing...more

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