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Office of the Comptroller of the Currency Risk Management

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

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The federal banking agencies have withdrawn previously issued guidance related to banks’ crypto activities, marking a shift in regulatory posture toward digital asset engagement.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

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

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

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

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

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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

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

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

Stinson LLP

CFPB and OCC Signal Strategic Shifts in Supervision and Enforcement

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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

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

Smith Anderson

From “Debanking” to Deregulation: A Turning Point for Reputational Risk

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Federal banking regulators are rapidly rewriting the playbook. In the early months of the second Trump administration, sweeping shifts in policy and supervisory priorities are already taking shape. One of the most...more

Mayer Brown

OCC Withdraws Climate Risk Management Principles

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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

Orrick, Herrington & Sutcliffe LLP

OCC withdraws climate risk guidelines for large banks

On March 31, the OCC announced that it had withdrawn from participating in the interagency principles for managing climate-related financial risks for large financial institutions....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

Latham & Watkins LLP

FDIC Removes Roadblocks to Crypto Activities in the Banking Sector

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New FDIC guidance permits crypto activities by supervised institutions without prior approval, emphasizing risk management and compliance with applicable laws and regulations....more

Troutman Pepper Locke

Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast

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In this episode of Payments Pros, host Carlin McCrory discusses a recent consent order between Patriot Bank and the Office of the Comptroller of the Currency (OCC) following a $27 million loss. The order addresses unsafe...more

Orrick, Herrington & Sutcliffe LLP

OCC reports improved mortgage performance in Q4 2024

On March 24, the OCC published its Mortgage Metrics Report for the fourth quarter of 2024. The Report analyzed the performance of first-lien residential mortgage loans serviced by seven national banks in the U.S. As of...more

Troutman Pepper Locke

OCC Ceases Examinations for Reputation Risk Following Legislative Push

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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

Sheppard Mullin Richter & Hampton LLP

OCC Eliminates “Reputational Risk” Category from Bank Supervision Criteria 

On March 20, the OCC announced that it will no longer treat reputation risk as a standalone category in its supervision of national banks and federal savings associations. The decision marks a dramatic shift in the agency’s...more

Sheppard Mullin Richter & Hampton LLP

OCC Signals Shift on Crypto and Debanking Under Acting Comptroller Hood 

On March 18, Acting Comptroller of the Currency Rodney Hood reiterated the OCC’s commitment to ensuring fair access to banking services, including for cryptocurrency firms. Speaking at a retail banking industry conference,...more

Orrick, Herrington & Sutcliffe LLP

OCC conditionally grants bank’s application for fintech purchase

On March 17, the OCC announced it had conditionally approved an application of a fintech to change the business model of a nationally chartered bank upon acquisition of the bank by the fintech, specifically allowing the...more

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