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NYDFS Proposes Updated Guidance on Crypto Listing

The Proposed Guidance would require enhanced criteria for coin-listing and delisting procedures for New York-licensed virtual currency entities. On September 18, 2023, the New York Department of Financial Services (DFS)...more

FRB Clarifies Supervision of Digital Assets and Bank-Fintech Partnerships

A new program addresses innovative banking activities such as bank-fintech partnerships and digital assets while reinforcing guardrails around stablecoin activity. On August 8, 2023, the Board of Governors of the Federal...more

FRB Vice Chair for Supervision Recommends Stronger Capital Standards for Large US Banks

After a lengthy “holistic” review and a spring banking crisis, US bank capital requirements finally face overhaul. On July 10, 2023, US Federal Reserve Board (FRB) Vice Chair for Supervision Michael Barr delivered a...more

FRB Governor Recommends Circumspect Approach to Bank Regulatory Reform

Governor Bowman calls for transparent supervisory expectations and attention to the consequences of regulatory reform on the broader financial system. On June 25, 2023, US Federal Reserve Board (FRB) Governor Michelle W....more

Agencies Issue Guidance for Banking Organizations on Managing Risk in Third-Party Relationships

The guidance outlines principles and key considerations for banking organizations as they navigate risks associated with third parties, including fintechs. On June 6, 2023, the Federal Deposit Insurance Corporation...more

Florida Law to Restrict the Use of Certain ESG Factors by Asset Managers and Financial Institutions

The legislation mirrors anti-“industry boycott” legislation introduced or passed in other US states and provides more explicit rubrics of prohibited factors. On May 5, 2023, Florida Governor Ron DeSantis signed into law...more

Global Regulators React to Banking Sector Turbulence

The spring of 2023 saw more dislocation in the global financial sector than any time since the 2008-09 financial crisis. In the US, banking institutions with over $500 billion in total assets failed, and other banks that were...more

New York Attorney General Proposes Stringent Crypto Bill

The CRPTO Act is intended to increase transparency and consumer protections, and reduce conflicts of interest, through heightened disclosures and penalties. On May 5, 2023, New York Attorney General (NYAG) Letitia James...more

US House Financial Services Committee Wrangles Over Stablecoins

Congress will be “starting from scratch” in attempting to establish a regulatory framework for stablecoins — an issue that many believe is the top digital asset legislative priority. On April 15, 2023, the US House...more

FDIC Vice Chairman Cautions Against New Regulation as a Response to Recent Bank Failures

In contrast with the White House’s position, the Vice Chairman denied that loosened Dodd-Frank rules contributed to the recent bank failures. On April 12, 2023, Federal Deposit Insurance Corporation (FDIC) Vice Chairman...more

White House Recommends Stricter Regulations for Large Regional Banks

President Biden is calling for tougher standards and supervision for large regional banks in the wake of recent instability in the US banking sector. On March 30, 2023, the White House issued a Fact Sheet calling on the...more

Blockchain Regulatory Certainty Act Would Protect Non-Custodial Crypto Services

The bipartisan bill would provide a federal safe harbor for non-custodial blockchain service providers from state money transmission and digital asset licensing laws. On March 23, 2023, US House of Representatives...more

Illinois Considering Crypto Licensing

A legislative initiative in Illinois would establish licensing and consumer protection requirements for digital asset businesses serving consumers in the state. On February 21, 2023, the Illinois Department of Financial...more

Wyoming Stable Token Act Enacted Into Law

By authorizing the issuance of a stable token, “Blockchain Valley” leads the way in state digital asset adoption and integration. For the last few years, Wyoming has been a leader among US states at the intersection of...more

Federal Reserve Establishes Bank Term Funding Program to Stabilize Financial System

The decisive action will mitigate emerging liquidity and solvency risks, contain pressure on the banking system, and protect depositors. On March 12, 2023, the Board of Governors of the Federal Reserve System (Federal...more

Federal Reserve Narrows the Crypto Activities of Member Banks

Custodia Bank was denied Federal Reserve membership, while certain crypto principal activities are deemed presumptively not appropriate for member banks. On January 27, 2023, the Board of Governors of the Federal Reserve...more

New York Department of Financial Services Issues Crypto Custody Guidance

The Guidance clarifies the regulator’s expectations on safekeeping customer digital assets, and the disclosures that must accompany such arrangements. On January 23, 2023, the New York Department of Financial Services...more

Acting Comptroller Confronts “Too Big to Manage” Issue

The Acting Comptroller of the OCC discussed the limits of large bank manageability and the steps that regulators can take to address the risks posed by size and complexity. On January 17, 2023, Acting Comptroller of the...more

Banking Regulators Issue Joint Statement on Crypto Risks

Banking organizations should ensure appropriate risk management, but regulators are skeptical of certain crypto activities as principal. On January 3, 2023, the Board of Governors of the Federal Reserve System (Federal...more

NYDFS Proposes Guidance on Climate Change Risk Management

The Guidance would increase expectations for regulated financial institutions to identify, measure, monitor, and control climate-related financial risks. For the past few years, the New York State Department of Financial...more

New York Department of Financial Services Issues Crypto Guidance for Banks

Digital asset activities of licensed institutions must be approved and will be assessed for potential safety and soundness risks. On December 15, 2022, the New York State Department of Financial Services (NYDFS) issued...more

Federal Reserve Proposes Climate Risk Guidance for Large Financial Institutions

The guiding principles are similar to related proposals from other banking regulators, but will require further clarification through the comment process. On December 2, 2022, the Board of Governors of the Federal...more

White House Issues Digital Asset Framework

The comprehensive framework, which spans multiple reports, aims to spur risk mitigation efforts and potentially a US central bank digital currency. On September 16, 2022, the White House published a fact sheet described...more

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