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Banking Sector Office of the Comptroller of the Currency Cryptocurrency

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - April 2024

Editor's Note The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically...more

Wilson Sonsini Goodrich & Rosati

Focus on Fintech – Q2 2023

In this most recent issue, we discuss a number of federal banking agency updates, including the long-awaited Final Interagency Guidance on Third-Party Relationships and the Federal Reserve Bank of New York’s report on the...more

Sheppard Mullin Richter & Hampton LLP

Hsu Suggests Caution in Rollout of AI and Tokenization in Banking

On June 16, Michael Hsu, the Acting Comptroller of the Currency gave remarks at the American Bankers Association’s Risk and Compliance Conference about the risks of tokenization and AI on the banking industry. While...more

Jenner & Block

Client Alert: Bank-Fintech Partnerships Update: Banking Agencies Finalize Key Risk Management Guidance

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On June 6, 2023, federal banking agencies issued final Interagency Guidelines on Third-Party Relationships detailing their expectations for banks in establishing risk management practices with third-parties—including...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

Katten Muchin Rosenman LLP

Bank/Fin-Tech Agreements: Re-Assessment Required Given New Regulatory Guidance on Third-Party Servicing Agreements

On June 6, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Federal Reserve), and the Federal Deposit Insurance Corporation (FDIC) (collectively, the Banking Agencies)...more

Orrick, Herrington & Sutcliffe LLP

Republicans accuse federal regulators of engaging in a “coordinated strategy” to de-bank digital asset ecosystem

On April 26, House Financial Services Committee Chairman Patrick McHenry (R-NC), Digital Assets, Financial Technology and Inclusion Subcommittee Chairman French Hill (R-AR), and Oversight and Investigations Subcommittee...more

White & Case LLP

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

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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

Jones Day

Fed Policy Statement Adds Hurdles to Digital Asset Activities and Innovation by State Banks

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In Short - The Situation: The Federal Reserve Board ("Board") has issued a new policy statement ("Policy Statement") imposing limits, including Board approval requirements, on digital asset activities and other novel...more

Wilson Sonsini Goodrich & Rosati

Demystifying the Banking Regulators’ Recent Crypto Actions: Key Takeaways for Fintech Companies

The last few years had started to see a convergence between crypto and banking, with bitcoin appearing to rapidly grow mainstream. That momentum hit a wall with the spectacular crypto market failures of 2022, including the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Recent Actions by the Fed Show Its Continued Cautious Approach to Cryptoasset Activities by Supervised Institutions

In the past year, the Board of Governors of the Federal Reserve System (the Board) Biden administration officials, and other U.S. banking regulators have repeatedly voiced growing concerns about certain cryptoasset...more

Sheppard Mullin Richter & Hampton LLP

Fed Board Denies Crypto Firm’s Bid to Join Federal Reserve System

On January 27, the Federal Reserve Board (FRB) announced that it unanimously voted to deny a crypto firm’s application to become a member of the Federal Reserve System. This denial ends the crypto firm’s 27-month effort to...more

Wilson Sonsini Goodrich & Rosati

Focus on Fintech – Q4 2022

In this latest issue of Wilson Sonsini's Focus on Fintech newsletter, we discuss the FTX bankruptcy and the increased federal regulatory scrutiny of crypto assets, and new rules and innovations in the payments...more

Latham & Watkins LLP

Banking Regulators Issue Joint Statement on Crypto Risks

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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

Jones Day

Bank Regulators Issue Joint Statement on Safety and Soundness of Crypto Activities

Jones Day on

In Short - The Situation: Since clarifying the legal permissibility of certain crypto activities in 2020 and early 2021, the Federal banking agencies have begun to tighten regulatory scrutiny of such activities, warning...more

WilmerHale

Prudential Regulators Issue New Guidance on Crypto-Assets

WilmerHale on

On January 3, the Board of Governors of the Federal Reserve (FRB), Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) issued a Joint Statement on Crypto-Asset Risks to Banking...more

Kramer Levin Naftalis & Frankel LLP

Federal Banking Regulators Issue Joint Statement on Crypto-Asset Risks to Banking Organizations

On Jan. 3, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) (collectively, the “Agencies”) issued a statement on...more

McGlinchey Stafford

OCC Advises “Careful and Cautious” Approach to FinTech-Bank Partnerships

McGlinchey Stafford on

On Wednesday, September 7, 2022, acting Comptroller of the Currency Michael J. Hsu gave remarks in New York City at the Clearing House + Bank Policy Institute Annual Conference. Hsu’s remarks, “Safeguarding Trust in Banking:...more

Venable LLP

ETA FinTech Policy Forum

Venable LLP on

​​​​​​​This note summarizes the federal regulator panels at ETA's annual FinTech Policy Forum, which was hosted by Venable in our Washington, DC office. We provide key takeaways from the discussions with (a) CFPB Director...more

Sheppard Mullin Richter & Hampton LLP

OCC Highlights Focus on Crypto and Bank-FinTech Partnerships, Anticipates Stricter Scrutiny Going Forward

On September 7, Acting Comptroller of the Currency, Michael Hsu, discussed the long-term threats to trust in banking in remarks at the TCH + BPI Annual Conference. Hsu provided updates on key priorities at the OCC, including...more

Ballard Spahr LLP

U.S. Senators ask OCC to reverse guidance on bank engagement in crypto-related activities

Ballard Spahr LLP on

On August 10, 2022, four Senators, Elizabeth Warren (D-MA), Dick Durbin (D-IL), Sheldon Whitehouse (D-RI), and Bernie Sanders (I-VT), sent a letter to Acting Comptroller of the Currency Michael Hsu, asking him to reverse four...more

Sheppard Mullin Richter & Hampton LLP

OCC Acting Comptroller: Recent Crypto Events Provide a “Wake-Up Call,” “Opportunity to Reset and Recalibrate”

On May 24, the acting Comptroller of the Currency, Michael Hsu remarked at the DC Blockchain Summit 2022 about his observations on the “deep” vulnerabilities of cryptocurrency in light of the recent market volatility and...more

Nutter McClennen & Fish LLP

Nutter Bank Report: May 2022

Federal Banking Agencies Issue CRA Modernization Proposal The federal banking agencies have jointly issued a proposed rule that would modernize their regulations that implement the Community Reinvestment Act (the “CRA”). The...more

Alston & Bird

U.S. Government Steps Up Its Enforcement in the Digital Assets Space

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Our Blockchain & Digital Assets Team offers a snapshot sample of significant recent developments by a panoply of federal agencies and departments that represent the expanding array of enforcement tools used by federal...more

A&O Shearman

OCC Issues Consent Order Against A Digital Bank

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On April 21, 2022, the Office of the Comptroller of the Currency (OCC) issued a consent order against Anchorage Digital Bank, a digital asset bank based in South Dakota. Notably, Anchorage had previously become the first...more

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