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WisdomTree Granted New York Limited Purpose Trust Company Charter

As federal regulation remains patchy, firms may want to consider a New York state charter as a potential avenue to expand digital asset offerings in a compliant manner. On March 22, 2024, WisdomTree, Inc., a global asset...more

FDIC Proposes Revisions to Policy on Bank Merger Transactions

The Proposal clarifies the FDIC’s bank merger approval process but may prove challenging for new large bank consolidations with the FDIC as the primary regulator. On March 21, 2024, the Board of Directors of the Federal...more

How Proposed Bipartisan Bill Would Reform Bank Exams

A recent bipartisan bill, if enacted, would particularly benefit small lenders and bank/fintech partnerships by promoting transparency, appellate rights and examiner accountability. On Dec. 14, 2023, a bipartisan group of...more

Banking Trade Groups Challenge New Community Reinvestment Act Regulation

Banking agencies are alleged to have exceeded their congressional authorization, with potentially adverse consequences on banks and consumers. On February 5, 2024, several banking trade groups[1] (the Plaintiffs) sued...more

CFPB Proposes to Prohibit Non-Sufficient Funds Fees on Declined Transactions

As person-to-person payments become mainstream, the proposal would proactively outlaw fees that financial institutions could assess on instantaneously declined transactions. On January 24, 2024, the Consumer Financial...more

Proposed Bill Would Reform Bank Exam Processes

A recent bipartisan bill, if enacted, would particularly benefit small lenders and bank-fintech partnerships by promoting transparency, appellate rights, and examiner accountability. On December 14, 2023, a bipartisan...more

OCC Issues Policy Guidance on Buy Now, Pay Later Lending

The OCC outlines safety and soundness principles and appropriate risk management processes for its regulated institutions that engage in BNPL lending. On December 6, 2023, the Office of the Comptroller of the Currency...more

New York Bolsters Cybersecurity Requirements

Covered financial institutions now face heightened expectations in relation to cybersecurity governance, risk assessment, and incident reporting. The New York State Department of Financial Services’ (DFS) amendments (the...more

OCC Issues Policy Guidance on Venture Loans

The OCC outlines safety and soundness principles and appropriate risk management processes for its regulated institutions that engage in venture lending. On November 1, 2023, the Office of the Comptroller of the Currency...more

FRB Proposes to Lower Debit Card Interchange Fee

A proposed rule would lower the maximum amount that large debit card issuers can charge merchants for each transaction. On October 25, 2023, the Board of Governors of the Federal Reserve System (FRB) published a proposal...more

OCC, FRB, and FDIC Finalize Joint Principles for Climate-Related Financial Risk Management

Guidance for the largest US financial institutions is intended to promote climate risk management consistent with general safety and soundness practices. On October 30, 2023, the three US federal bank regulatory agencies...more

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

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