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President Trump Issues Executive Order on Fair Banking

Regulators are directed to avoid reputation risk, identify banks that have engaged in unlawful debanking, and take appropriate remedial actions. ...more

Banking Agencies Issue Joint Statement on Risk-Management Considerations for Cryptoasset Safekeeping

Banking organizations safekeeping digital assets for customers must do so in a safe and sound manner and in compliance with applicable laws and regulations....more

OCC Bank Merger Rule Rescinded in Latest Regulatory Reversal

The OCC is restoring its former practices and policies under the Bank Merger Act to reinstate expedited merger reviews and streamlined business combination applications....more

OCC Affirms Banks Can Engage in Crypto Custody and Execution Activities

The federal banking agencies continue to open the channels for regulated entities to engage in digital asset activities. On May 7, 2025, the Office of the Comptroller of the Currency (OCC) published Interpretive Letter...more

OCC Affirms Regulated Entities Can Engage in Crypto and Stablecoin Activities

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

FDIC Acting Chairman Charts a Fresh Path Forward for the Agency

The FDIC seeks to stick to its statutory mandate while reducing impediments to fintech, innovation, mergers, bank formation, and efficient supervision....more

The Tides Are Changing (Again) for US “Fair Access” and “Anti-Debanking” Laws

“Fair access” banking laws, at the epicenter of the debates between ESG and “anti-woke” regulation and federal/state preemption, may see a resurgence under the incoming administration. In recent years, the landscape of...more

CFPB Finalizes Open Banking Rule

The rule aims to reduce market concentration by guaranteeing consumer access to personal financial data, but faces strident criticism and immediate legal challenge....more

FDIC, OCC Finalize Policy on Bank Merger Transactions

Regulators seek to provide clarity and transparency on the bank merger review process, but changes may increase application complexity and unpredictability. Consistent with ongoing initiatives to strengthen US antitrust...more

FDIC Proposes Amendments to Its Change in Bank Control Act Regulations

The proposal would establish stricter oversight of certain transactions and responds to concerns that large asset managers may be exerting influence on FDIC-supervised institutions. On July 30, 2024, the Board of...more

Agencies Issue Joint Proposal to Amend Bank Secrecy Act Compliance Programs for Banks

On July 19, 2024, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the National Credit Union Administration...more

FRB Issues Report on Climate Scenario Analysis Pilot

With regulators keeping close watch, the results underscore the need for ongoing climate risk management investment and adaptation within the financial sector. On May 9, 2024, the Board of Governors of the Federal...more

Banking Trade Groups Challenge New Community Reinvestment Act Regulation

Banking agencies are alleged to have exceeded their congressional authorization, with potentially adverse consequences on banks and consumers. On February 5, 2024, several banking trade groups[1] (the Plaintiffs) sued...more

CFPB Proposes to Prohibit Non-Sufficient Funds Fees on Declined Transactions

As person-to-person payments become mainstream, the proposal would proactively outlaw fees that financial institutions could assess on instantaneously declined transactions. On January 24, 2024, the Consumer Financial...more

CFPB Proposes to Regulate Large Digital Wallet and Payment App Providers

The proposal would subject certain large non-bank companies offering wallet and payment services to federal regulatory oversight on par with banks and credit unions. On November 7, 2023, the Consumer Financial Protection...more

New York Bolsters Cybersecurity Requirements

Covered financial institutions now face heightened expectations in relation to cybersecurity governance, risk assessment, and incident reporting. The New York State Department of Financial Services’ (DFS) amendments (the...more

OCC Issues Policy Guidance on Venture Loans

The OCC outlines safety and soundness principles and appropriate risk management processes for its regulated institutions that engage in venture lending. On November 1, 2023, the Office of the Comptroller of the Currency...more

FRB Proposes to Lower Debit Card Interchange Fee

A proposed rule would lower the maximum amount that large debit card issuers can charge merchants for each transaction. On October 25, 2023, the Board of Governors of the Federal Reserve System (FRB) published a proposal...more

OCC, FRB, and FDIC Finalize Joint Principles for Climate-Related Financial Risk Management

Guidance for the largest US financial institutions is intended to promote climate risk management consistent with general safety and soundness practices. On October 30, 2023, the three US federal bank regulatory agencies...more

FRB Clarifies Supervision of Digital Assets and Bank-Fintech Partnerships

A new program addresses innovative banking activities such as bank-fintech partnerships and digital assets while reinforcing guardrails around stablecoin activity. On August 8, 2023, the Board of Governors of the Federal...more

Federal Reserve Launches FedNow Real-Time Payment Service

Consumers and businesses stand to benefit from rapid access to funds at any time when routed through participating financial institutions. On July 20, 2023, the Federal Reserve announced the long-awaited launch of its...more

FRB Vice Chair for Supervision Recommends Stronger Capital Standards for Large US Banks

After a lengthy “holistic” review and a spring banking crisis, US bank capital requirements finally face overhaul. On July 10, 2023, US Federal Reserve Board (FRB) Vice Chair for Supervision Michael Barr delivered a...more

Agencies Issue Guidance for Banking Organizations on Managing Risk in Third-Party Relationships

The guidance outlines principles and key considerations for banking organizations as they navigate risks associated with third parties, including fintechs. On June 6, 2023, the Federal Deposit Insurance Corporation...more

Florida Law to Restrict the Use of Certain ESG Factors by Asset Managers and Financial Institutions

The legislation mirrors anti-“industry boycott” legislation introduced or passed in other US states and provides more explicit rubrics of prohibited factors. On May 5, 2023, Florida Governor Ron DeSantis signed into law...more

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