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A New “Operation Choke Point”? The Quickly Changing Rules on Crypto Activities for Member Banks

In an effort to align the permissibility of crypto activities for all member banks of the Federal Reserve System (the "FRS", which includes all national banks and state member banks), the Board of Governors of the Federal...more

UnSound: OCC IL 1179 and Its Backwards Creation of New Law

On November 23, 2021, the Chief Counsel and Senior Deputy Comptroller Benjamin W. McDonough of the Office of the Comptroller of the Currency (the "OCC") issued OCC Interpretive Letter 1179 (dated November 18, 2021) ("IL...more

Unstable: the PWG's Report on Stablecoins

On November 1, 2021, the President's Working Group on Financial Markets (the "PWG"), the Federal Deposit Insurance Corporation (the "FDIC") and the Office of the Comptroller of the Currency (the "OCC") issued a Report on...more

Stabilized: OCC settles debate about regulatory characterization of bank-issued stablecoins

On January 4, 2021, the Chief Counsel of the Office of the Comptroller of the Currency ("OCC") issued an interpretive letter ("IL 1174") on the permissibility of national banks to use independent node verification networks...more

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