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Enforcement to Endorsement: Digital Asset Executive Order and SAB 121 Rescission

President Trump signed an executive order ("EO") titled "Strengthening American Leadership in Digital Financial Technology" that signals a radical shift in the federal government's posture towards digital assets and the...more

FDIC Proposes New Requirements for Custodial Accounts to Qualify for Pass-Through

The Situation: On September 17, 2024, the Federal Deposit Insurance Corporation ("FDIC") approved a proposed rule ("the Proposal") that would establish new recordkeeping requirements for FDIC-insured depository institutions...more

CFPB Seeks to Expand Regulatory Powers Over Consumer Payment Tech Entities

On November 7, 2023, the Consumer Financial Protection Bureau ("CFPB") issued a proposed rule that would grant it supervisory authority over major nonbank technology companies in the consumer digital payments space....more

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