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

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

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

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

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