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Financial Institutions Office of the Comptroller of the Currency Regulatory Requirements

Ballard Spahr LLP

OCC, FDIC eliminating ‘reputational risk’ from supervision, examinations

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The OCC has removed “reputational risk” from its handbooks and guidance and the FDIC is moving to do the same. ...more

Orrick, Herrington & Sutcliffe LLP

OCC provides an update on its security breach given institutional risk

On April 14, the OCC released a letter providing more details on the recent security breach involving its email systems. The breach — identified as a major incident under the Federal Information Security Modernization Act...more

Paul Hastings LLP

Daily Financial Regulation Update -- Monday, April 21, 2025

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April 18, 2025 - The Federal Reserve and the Office of the Comptroller of the Currency have conditionally approved the merger of Discover Bank, Greenwood, Delaware, into Capital One, National Association, McLean, Virginia....more

Paul Hastings LLP

Daily Financial Regulation Update -- Thursday, April 17, 2025

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April 16, 2025 - The U.S. Department of the Treasury released Treasury International Capital (TIC) data for February 2025. The next release, which will report on data for March 2025, is scheduled for May 16, 2025....more

Alston & Bird

Federal Banking Agencies Announce Intent to Rescind 2023 Community Reinvestment Act Final Rule and Return to Prior Framework

Alston & Bird on

What Happened? The Federal Deposit Insurance Corporation (“FDIC”), Board of Governors of the Federal Reserve System (“Federal Reserve”) and the Office of the Comptroller of the Currency (“OCC”), (collectively, “federal...more

Troutman Pepper Locke

OCC Notifies Congress of Major Email System Security Breach

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On April 8, the Office of the Comptroller of the Currency (OCC) officially notified Congress of a significant information security incident involving its email system. This notification, mandated by the Federal Information...more

Mayer Brown

FDIC Streamlines Process for Cryptocurrency Activities by Banks It Regulates and Speculates on Additional Permissible Activities

Mayer Brown on

On March 28, 2025, the Federal Deposit Insurance Corporation (FDIC) issued guidance on state nonmember bank and state savings association participation in certain cryptocurrency activities (“FIL-7-2025”). ...more

Sheppard Mullin Richter & Hampton LLP

Federal Regulators Signal Reversal on 2023 CRA Modernization Rule

On March 28, the Federal Reserve, FDIC, and OCC jointly announced plans to rescind 2023 revisions to the Community Reinvestment Act (CRA) regulations. The agencies stated they would return to the previous regulatory framework...more

Jones Day

OCC Ends Climate Risk Guidance for Large Banks

Jones Day on

In a recent shift, the Office of the Comptroller of the Currency (OCC) has officially ended its climate risk guidance for large U.S. banks. The 2021 guidance called on major banks to incorporate climate-related risks into...more

Jones Day

FDIC Rescinds Prior Notification Requirement for Banks' Permissible Crypto Activities

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The FDIC has rescinded an earlier Financial Institution Letter establishing a prior notification requirement for FDIC-supervised institutions that wish to engage in specified crypto-related activities and has clarified that...more

Katten Muchin Rosenman LLP

Banking Agencies Begin Publishing Updated Crypto Guidance

On March 28, the Federal Deposit Insurance Corporation (FDIC) rescinded Biden administration guidance related to state-chartered banks' participation in "crypto-related activities" and published a new interpretation of the...more

BakerHostetler

Cooking Up Compliance: Navigating the Alphabet Soup of Financial Privacy

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Like a health inspection sticker in a restaurant’s front window, a GLBA privacy notice must provide clear and conspicuous disclosures about a financial institution’s practices relating to nonpublic personal information (NPI)....more

Stinson LLP

OCC Charts a New Path for FinTech Banking

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On March 17, the Office of the Comptroller of the Currency (OCC) announced that the agency granted conditional approval for a leading FinTech company to indirectly acquire a nationally chartered bank, enabling the FinTech...more

Brownstein Hyatt Farber Schreck

Regulating Digital Dollars: How Federal Bills Stack Up

In November of 2021, the President’s Working Group on Financial Markets, joined by the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC), issued a report formally...more

Orrick, Herrington & Sutcliffe LLP

OCC conditionally grants bank’s application for fintech purchase

On March 17, the OCC announced it had conditionally approved an application of a fintech to change the business model of a nationally chartered bank upon acquisition of the bank by the fintech, specifically allowing the...more

Orrick, Herrington & Sutcliffe LLP

OCC releases March 2025 enforcement actions

On March 20, the OCC released a list of recent enforcement actions taken against national banks, federal savings associations, and individuals affiliated with supervised banks. Among the actions taken, the OCC issued a cease...more

Ballard Spahr LLP

Crypto Clarity: OCC’s New Guidelines Pave the Way for Banking Innovation

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On March 7, 2025, the Office of the Comptroller of the Currency (“OCC”) released Interpretive Letter 1183, marking a pivotal change in regulatory guidance for national banks and federal savings associations engaging in...more

Latham & Watkins LLP

OCC Affirms Regulated Entities Can Engage in Crypto and Stablecoin Activities

Latham & Watkins LLP on

In a break from restrictive Biden-era policies, OCC-supervised banks may now engage in crypto without supervisory nonobjection, potentially opening new avenues for innovation....more

Sheppard Mullin Richter & Hampton LLP

OCC Clarifies Banks’ Role in Cryptocurrency Activities

On March 7, the OCC issued Interpretive Letter 1183 and an accompanying statement affirming prior guidance regarding whether national banks and federal savings associations may engage in cryptocurrency-related activities,...more

Troutman Pepper Locke

OCC Clarifies Bank Authority to Engage in Certain Cryptocurrency Activities

Troutman Pepper Locke on

On March 7, the Office of the Comptroller of the Currency (OCC) issued a significant update regarding the involvement of national banks and federal savings associations in cryptocurrency activities. Interpretive Letter 1183...more

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 57: Opening a Path for New Bank Formations

The Klaros Group’s Michele Alt joins Orrick partners Jerry Buckley, Caroline Stapleton and Walt Zalenski to explore actions needed to facilitate new bank formations, which have slowed to trickle in recent years. The...more

Jones Day

OCC Eases Some Restrictions on Bank Digital Asset Activities

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In recent years, U.S. federal bank regulators significantly limited banks' authority to engage in crypto-asset activities, including participating in public blockchains, owning digital assets as principal, and even providing...more

Davis Wright Tremaine LLP

OCC Rescinds Required Supervisory "Non-Objection" Preclearance for Permissible Crypto-Related Activities

The OCC has reiterated that certain crypto-related activities—crypto-asset custody, distributed ledger, and stablecoin activities—previously determined to be permissible remain so. The OCC has also rescinded a Biden-era...more

Ballard Spahr LLP

FDIC proposing rescinding merger policy adopted in September

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The FDIC has proposed rescinding the agency’s 2024 Statement of Policy on Bank Merger Transactions. FDIC officials said at the time of issuance that the Statement of Policy addresses the scope of transactions that will be...more

Orrick, Herrington & Sutcliffe LLP

OCC reportedly orders all employees to return to the office

On March 5, the OCC has reportedly ordered all employees to “return to the office” at the end of the month. As part of the order, all OCC employees will have to report to the respective office within 50 miles of their...more

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