News & Analysis as of

Risk Management Digital Assets Office of the Comptroller of the Currency

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

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

Ballard Spahr LLP

Crypto Clarity: OCC’s New Guidelines Pave the Way for Banking Innovation

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On March 7, 2025, the Office of the Comptroller of the Currency (“OCC”) released Interpretive Letter 1183, marking a pivotal change in regulatory guidance for national banks and federal savings associations engaging in...more

Wilson Sonsini Goodrich & Rosati

A Crypto-Friendly Pivot in Bank Supervision: Three Practical Action Items for Innovators

A federal banking agency, the Office of the Comptroller of the Currency (OCC), has smoothed the way for national banks and federal savings associations to engage in crypto-related activities with the issuance of Interpretive...more

Sheppard Mullin Richter & Hampton LLP

OCC Clarifies Banks’ Role in Cryptocurrency Activities

On March 7, the OCC issued Interpretive Letter 1183 and an accompanying statement affirming prior guidance regarding whether national banks and federal savings associations may engage in cryptocurrency-related activities,...more

Troutman Pepper Locke

OCC Clarifies Bank Authority to Engage in Certain Cryptocurrency Activities

Troutman Pepper Locke on

On March 7, the Office of the Comptroller of the Currency (OCC) issued a significant update regarding the involvement of national banks and federal savings associations in cryptocurrency activities. Interpretive Letter 1183...more

Davis Wright Tremaine LLP

OCC Rescinds Required Supervisory "Non-Objection" Preclearance for Permissible Crypto-Related Activities

The OCC has reiterated that certain crypto-related activities—crypto-asset custody, distributed ledger, and stablecoin activities—previously determined to be permissible remain so. The OCC has also rescinded a Biden-era...more

Latham & Watkins LLP

Competing Stablecoin Bills Reflect Consensus and Divergence on Key Issues

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Stablecoin regulation is a top priority for lawmakers, and three recent proposals reflect differing perspectives on how to achieve regulatory clarity while balancing safety and innovation....more

Paul Hastings LLP

PHFintech: Crypto Policy Tracker - December 13, 2024

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A significant headwind for companies in the digital asset space is that they have reportedly struggled to secure and maintain relationships with banks, in what is now called “Choke Point 2.0.” With the incoming Trump...more

K2 Integrity

Crypto in a Time of Uncertainty

K2 Integrity on

On 07 June 2023, K2 Integrity hosted a webinar on the state of cryptocurrency and digital assets in a rapidly evolving regulatory landscape. A discussion was held with Bryan Stirewalt, senior managing director at K2...more

Orrick, Herrington & Sutcliffe LLP

Agencies warn banks of crypto-asset liquidity risks

On February 23, the FDIC, Federal Reserve Board, and OCC released a joint statement addressing bank liquidity risks tied to crypto-assets. The agencies warned that using sources of funding from crypto-asset-related entities...more

Goodwin

CFPB Launches New Initiative Focused on Rural Communities

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In This Issue. The Consumer Financial Protection Bureau (CFPB) announced a new initiative focused on financial issues faced by rural communities and also updated its examination procedures to cover unfair discrimination; the...more

Goodwin

FinCEN Warns Against Evasion of Russian Sanctions

Goodwin on

In this Issue. The Financial Crimes Enforcement Network (FinCEN) published an alert warning financial institutions of possible efforts to evade U.S.-imposed sanctions on Russia and Belarus; the U.S. Department of the Treasury...more

K2 Integrity

Crypto and Virtual Currency Risks

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The ABA/ABA Financial Crimes Enforcement Conference took place January 11-13, with K2 Integrity Managing Director Gabriel Hidalgo, who leads the firm’s Crypto and Fintech Advisory practice, leading an important conversation...more

Perkins Coie

Fintech Legal Report - August 2021

Perkins Coie on

Senators Inquire about CFPB’s Fintech Agenda - On July 27, 2021, Senator Sherrod Brown, the Chairman of the U.S. Senate Committee on Banking, Housing, and Urban Affairs, sent a letter to the Consumer Financial Protection...more

Goodwin

OCC Reconsiders Controversial Revisions to CRA Rules

Goodwin on

In This Issue. The Office of the Comptroller of the Currency (OCC) announced that it will reconsider its controversial June 2020 final rule revising its Community Reinvestment Act (CRA) rules, and published its Semiannual...more

Nutter McClennen & Fish LLP

Fintech in Brief: FDIC Solicits Information on Digital Assets

On May 17, 2021, the Federal Deposit Insurance Corporation (the “FDIC”) issued a Request for Information and Comment (the “RFI”) on Digital Assets. The FDIC is interested in getting input from all interested parties on the...more

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