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New Virginia Law Permits Banks to Provide Virtual Currency Custody Services

On April 11, Virginia enacted a new law (HB 263), which goes into effect on July 1, 2022, permitting “banks” to provide customers with “virtual currency custody services so long as the bank has adequate protocols in place to...more

Power Struggle at the FDIC Board Becomes Public

In a CFPB blog post from December 9, the CFPB stated that the FDIC Board of Directors (FDIC Board) had promulgated a request for information (RFI) regarding a review of the Bank Merger Act criteria for approving bank mergers...more

The Rise of Cryptocurrency for Banks

On July 22, 2020, the Office of the Comptroller of the Currency (the OCC) confirmed in Interpretive Letter #1170 the authority of a national bank to provide cryptocurrency custody services. Since that time, the OCC has issued...more

Model Risk Management and Its Implications Under the Bank Secrecy Act

On April 9, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies), in consultation with the Financial...more

Considerations When Contemplating a Branch Consolidation and/or Closure Initiative

Prior to the COVID-19 pandemic, many combined factors pushed the banking industry toward consolidation, greater efficiency, and in many instances, smaller branch footprints. When COVID-19 forced banks to close branch lobbies...more

Update: Federal Reserve's Revised Control Framework Now Effective and New FAQs Issued

New Rule Effective as of September 30 - The Federal Reserve’s revised control framework under the Bank Holding Company Act (BHCA) and Home Owners’ Loan Act (HOLA) issued on January 30, 2020 became effective on September 30...more

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