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OCC Proposal and Policy Statement on Bank Mergers Could Freeze the Banking Industry in Place

The Situation: On January 29, 2024, the Office of the Comptroller of the Currency ("OCC") requested comment on a proposed rule updating its bank merger rules and incorporating a policy statement (the "Proposal") on agency...more

Final Climate Risk Guidance Ensures Supervisory Focus from Banking Agencies in 2024

The Situation: In October 2023, the Office of the Comptroller of the Currency ("OCC"), Federal Reserve System, and Federal Deposit Insurance Corporation ("FDIC," and the three agencies collectively, "Agencies") finalized...more

Federal Banking Agencies Propose Long-Term Debt Requirements for Large Banks

In Short: The Situation: The Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (collectively, the "Agencies") have proposed rules...more

Fed Policy Statement Adds Hurdles to Digital Asset Activities and Innovation by State Banks

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

Bank Regulators Issue Joint Statement on Safety and Soundness of Crypto Activities

In Short - The Situation: Since clarifying the legal permissibility of certain crypto activities in 2020 and early 2021, the Federal banking agencies have begun to tighten regulatory scrutiny of such activities, warning...more

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