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As Federal Government Works to Liberalize the Crypto Payment Regulatory Regime, Federal Reserve Eliminates Specialty Supervisory...

In its Client Alert of August 4, 2025, Buchalter discussed the new Genius Act creating a regulatory regime for stable coin payments, and other steps as the federal government looks to create a more favorable crypto currency...more

OCC and FDIC “Valid When Made” Rule Reaffirmed: Interest Rate Limitations, or Lack Thereof, on Loans Made By National and State...

Under the long-recognized valid when made doctrine, if a loan was not subject to a state usury law when it was made, it does not subsequently become even if it is subsequently sold or assigned to another party. The doctrine...more

CFPB Further Defines Abusiveness Standard; Expresses Intent to Limit Duplicative Enforcement

In a Policy Statement effective on January 24, 2020, the CFPB addresses perceived uncertainty as to the scope and meaning of the abusiveness standard, and that the CFPB had in various enforcement actions asserted claims for...more

OCC and FDIC Propose New Community Reinvestment Act Rules

On December 12, the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) issued a proposed rule that would result in major changes to the rules applying the Community...more

FDIC Issues Proposed Rule Clarifying “Valid-When-Made” Doctrine for State Banks, to Match OCC Proposed Rule for National Banks

On November 19, the Federal Deposit Insurance Corporation issued a Notice of Proposed Rulemaking (FDIC Notice) setting forth a proposed rule that, if ultimately adopted, would confirm that the “valid-when-made” doctrine...more

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