On November 7, 2023, the Consumer Financial Protection Bureau ("CFPB") proposed a new rule, to be codified at 12 C.F.R. § 1090.109, that would bring general-use digital payment processors who process more than five million...more
11/28/2023
/ Broker-Dealer ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Cryptocurrency ,
Debit Cards ,
Electronic Payment Transactions ,
Financial Services Industry ,
FinTech ,
Proposed Rules ,
Securities and Exchange Commission (SEC) ,
Technology Sector
On March 10, 2023 the California Department of Financial Protection and Innovation ("CDFPI") closed Silicon Valley Bank ("SVB"), a California chartered, non-member bank. The CDFPI placed SVB into receivership and appointed...more
10/5/2023
/ Banking Sector ,
Banks ,
Borrowers ,
California ,
Deposit Insurance ,
Depository Institutions ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Legislative Agendas ,
Regulatory Agenda ,
U.S. Treasury
On Friday, March 10, 2023, the California Department of Financial Protection and Innovation closed Silicon Valley Bank ("SVB") and the Federal Deposit Insurance Corporation ("FDIC") was appointed SVB's receiver....more
3/15/2023
/ Banking Sector ,
Banks ,
Deposit Accounts ,
Deposit Insurance ,
Depository Institutions ,
FDIC ,
Federal Reserve ,
Financial Crisis ,
Financial Institutions ,
Insolvency ,
Receivership ,
Relief Measures ,
Silicon Valley
On Friday, March 10, 2023, the Federal Deposit Insurance Corporation (“FDIC”) was appointed the receiver for Silicon Valley Bank (“SVB”). The FDIC created the Deposit Insurance National Bank of Santa Clara (“DINB”) and...more
3/13/2023
/ Banking Sector ,
Banks ,
Deposit Accounts ,
Deposit Insurance ,
Depository Institutions ,
FDIC ,
Federal Reserve ,
Financial Crisis ,
Financial Institutions ,
Receivership ,
Silicon Valley ,
U.S. Treasury
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
2/15/2023
/ Banking Sector ,
Cryptocurrency ,
Digital Currency ,
FDIA ,
Federal Reserve ,
Fiduciary Duty ,
Financial Institutions ,
FRB ,
Joint Statements ,
OCC ,
Popular ,
Trading Policies
With a new operational resilience framework in force in the UK and similar reforms proposed in the EU and the US, we examine how the regimes compare and their practical impact on financial services firms....more
12/5/2022
/ Bank of England ,
Banks ,
Basel Committee on Banking Supervision (BCBS) ,
Cyber Incident Reporting ,
Cybersecurity ,
EU ,
European Commission ,
Federal Deposit Insurance Act ,
FFIEC ,
Financial Conduct Authority (FCA) ,
Financial Services Industry ,
Infrastructure ,
IOSCO ,
Natural Disasters ,
New Rules ,
Prudential Regulation Authority (PRA) ,
UK
As current blockchain technology faces accusations of inefficiency and unsustainability, a new technology is finding its way to counteract them.
Blockchain -
Crypto blockchains are a highly discussed topic. Blockchain is...more
The Board of Governors of the Federal Reserve (the "Federal Reserve") has over several decades defined when an activity engaged in by foreign banks subject to the Bank Holding Company Act of 1956 (the "BHCA"), which are thus...more
As with any new phenomenon, the rise of digital assets has created a new lexicon. "Blockchain," "tokens," and "coins" are now household vocabulary. Central to the discussion are a set of assets generally classified as...more
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
Challenges and opportunities in the US, UK and Europe -
"Many Fintechs that previously avoided bank-like regulation in the US are now actively seeking that status."
The digital revolution was well underway long before most...more
11/17/2021
/ Banking Sector ,
Coronavirus/COVID-19 ,
Cryptocurrency ,
Digital Services ,
EU ,
Financial Services Industry ,
FinTech ,
Licenses ,
Popular ,
Sandbox ,
Technology Sector ,
UK
On November 1, 2021, the President's Working Group on Financial Markets (the "PWG"), the Federal Deposit Insurance Corporation (the "FDIC") and the Office of the Comptroller of the Currency (the "OCC") issued a Report on...more
There has been recent speculation that banks are about to enter the cryptocurrency markets. This makes a lot of commercial sense: There clearly is customer demand for banks to offer services similar to those they offer for...more
6/7/2021
/ Bank Holding Company Act ,
Banking Sector ,
Bitcoin ,
Blockchain ,
CFTC ,
Commodity Exchange Act (CEA) ,
Cryptocurrency ,
Digital Assets ,
Distributed Ledger Technology (DLT) ,
Federal Reserve ,
Volcker Rule
On January 4, 2021, the Chief Counsel of the Office of the Comptroller of the Currency ("OCC") issued an interpretive letter ("IL 1174") on the permissibility of national banks to use independent node verification networks...more
On December 27, 2020, the President signed into law the Consolidated Appropriations Act, 2021.Title X of Division N of that law ("Title X") contains several provisions that change the authority of the Board of Governors of...more