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Cryptocurrency Office of the Comptroller of the Currency Banks

Troutman Pepper

Will Resiliency Carry the Digital Asset Sector Through 2024?

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In 2023, the digital asset industry demonstrated remarkable resilience amidst significant challenges, including the dissolution of several digital asset financial services companies, numerous bank failures, and a $4.7 billion...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

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

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

Cadwalader, Wickersham & Taft LLP

Banking Agencies Issue Joint Statement on Crypto-related Liquidity Risks

Earlier yesterday, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”) issued a “Joint Statement on Liquidity Risks to Banking Organizations...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

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

Orrick, Herrington & Sutcliffe LLP

Agencies warn banks of crypto-asset risks

On January 3, the FDIC, Federal Reserve Board, and OCC issued a joint interagency statement highlighting key risks banks should consider when choosing to engage in cryptocurrency-related services. ...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Regulators Express Concern About Banks’ Exposure to Cryptoasset Risks

On January 3, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) issued a Joint Statement on...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

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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

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

BakerHostetler

US Banks Launch New Stablecoin; NFT Markets Expand; OCC Promotes Stablecoin Regulation; Blockchain Networks Evolve; Exchange...

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US Banks Launch New Stablecoin, Data Shows Increasing Interest in Crypto - In a recent press release, an association of FDIC-insured financial institutions announced the launch of the USDF Consortium (Consortium). The...more

BakerHostetler

Financial Firms Plan Decentralized Exchange, Launch Digital Bond; NFTs Launch in Sports, Fashion; Blockchain Tracing Solutions...

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US and Swiss Financial Firms Announce Decentralized Exchange, Digital Bond - A major U.S. fintech and digital payments company recently released a white paper detailing tbDEX, a new decentralized protocol for exchanging...more

Sheppard Mullin Richter & Hampton LLP

OCC Chief Counsel Clarifies Bank Authority to Engage in Crypto

On November 18, the Chief Counsel of the Office of the Comptroller of the Currency (OCC) issued a fourth interpretive letter (Letter 1179) regarding whether it is permissible for national banks and federal savings...more

White & Case LLP

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

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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

Ballard Spahr LLP

Federal banking agencies Issue “Crypto Asset Roadmap” for 2022 guidance; OCC confirms prior interpretive letters on crypto (but...

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The Federal Reserve Board, FDIC, and OCC (collectively, the “Agencies”) issued on November 23 a short Joint Statement on Crypto-Asset Policy Sprint Initiative and Next Steps (“Joint Statement”), which announced – without...more

Sheppard Mullin Richter & Hampton LLP

Banking Agencies Provide Crypto-Asset Roadmap as a Result of Interagency “Policy Sprints”

On November 23, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency (“banking agencies”) released a joint statement recognizing that the...more

Sheppard Mullin Richter & Hampton LLP

Modernize the Bank Regulatory Perimeter on Bank-Fintech Partnerships

Building on his remarks to the Blockchain Association and the American Fintech Council earlier this month, the Acting Comptroller of the Currency, Michael J. Hsu, issued a statement on November 16 before the Federal Reserve...more

Troutman Pepper

The Rise of Cryptocurrency for Banks

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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

Robins Kaplan LLP

Financial Daily Dose 4.26.2021 | Top Story: Bitcoin Bounces Back Over 50k

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Bitcoin’s back (and no, it never really left), thanks to a rally this morning that pushed its value up as much as 10% at one point in early trading today. Elon Musk’s weekend tweeting and news that presumptive top NFL draft...more

Nelson Mullins Riley & Scarborough LLP

Talking Custody of Digital Assets

I had the pleasure of presenting at Bank Director Magazine's Inspired By Acquire or Be Acquired: What Officers and Directors Need to Know Now virtual conference, along with Rick Levin, earlier this month. Our...more

Nelson Mullins Riley & Scarborough LLP

Brian Brooks' Last Dance

So let’s dance this last dance. On Jan. 4, 2021, the Office of the Comptroller of the Currency (“OCC”) published a Chief Counsel’s Interpretative Letter (the “Letter”) ‎confirming the authority of national banks’ and federal...more

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