On August 5, 2025, the Division of Corporation Finance of the U.S. Securities and Exchange Commission ("SEC") issued a statement ("Statement") providing interpretive clarity on the application of federal securities laws to...more
8/11/2025
/ Blockchain ,
Cryptoassets ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
New Guidance ,
Regulatory Oversight ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Transactions
The White House has issued an AI Action Plan that aims to position the United States as the leader in artificial intelligence ("AI"), as part of a broader pattern of boosting innovation and reducing regulatory burden, with...more
8/4/2025
/ Artificial Intelligence ,
Banks ,
Consumer Financial Protection Bureau (CFPB) ,
FDIC ,
Federal Funding ,
Federal Reserve ,
Financial Regulatory Reform ,
Financial Services Industry ,
Innovative Technology ,
Machine Learning ,
OCC ,
Regulatory Agenda ,
Regulatory Oversight ,
Regulatory Reform ,
Trump Administration
Banking agencies and the DOJ have signaled an openness to bank M&A where the combined institutions will enhance competition, customer benefits, technological innovation, and enterprise risk management....more
7/31/2025
/ Acquisition Agreements ,
Antitrust Provisions ,
Banks ,
Department of Justice (DOJ) ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Merger Agreements ,
Merger Controls ,
Trump Administration
Following the recent focus on two major regulatory frameworks—the Guiding and Establishing National Innovation for U.S. Stablecoins Act (known as the GENIUS Act) in the United States, and Regulation (EU) 2023/1114 of the...more
7/28/2025
/ Cryptocurrency ,
Digital Assets ,
EU ,
Financial Markets ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
New Legislation ,
Regulatory Oversight ,
Regulatory Reform ,
Regulatory Requirements ,
Stablecoins ,
The GENIUS Act
The GENIUS Act's passage marks the first major crypto legislation approved by both chambers of Congress, signaling a significant step toward regulatory clarity for stablecoins, while the CLARITY Act's advancement by the House...more
7/22/2025
/ Bipartisan Agreement ,
CFTC ,
Commodities ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Financial Markets ,
Investment ,
New Legislation ,
Pending Legislation ,
Regulatory Agenda ,
Regulatory Oversight ,
Regulatory Reform ,
Securities and Exchange Commission (SEC) ,
Stablecoins ,
The GENIUS Act ,
U.S. House
Federal banking regulators continue to promote a more "crypto-positive" regulatory environment through recent joint guidance issued to clarify risk management and compliance expectations for banks providing crypto-asset...more
7/16/2025
/ Anti-Money Laundering ,
Banks ,
Consumer Financial Products ,
Cryptoassets ,
Cryptocurrency ,
Cybersecurity ,
Digital Assets ,
FDIC ,
Federal Reserve ,
Financial Regulatory Reform ,
Financial Services Industry ,
Investment ,
OCC ,
Popular ,
Regulatory Requirements ,
Risk Management
The vote marks the first time the U.S. Senate has passed significant digital asset legislation and puts the industry one step closer to regulatory clarity for certain stablecoins....more
6/23/2025
/ Banks ,
Cryptocurrency ,
Digital Assets ,
Financial Institutions ,
Financial Regulatory Reform ,
FinTech ,
Popular ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Requirements ,
Stablecoins ,
U.S. Treasury
U.S. House lawmakers introduced the bipartisan CLARITY Act of 2025 proposing a comprehensive regulatory framework for digital assets that would delineate agencies' oversight roles, establish a provisional registration regime...more
6/4/2025
/ Blockchain ,
CFTC ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Financial Regulatory Reform ,
FinTech ,
Investment ,
Popular ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Oversight ,
Regulatory Reform
A May 29, 2025, U.S. Securities and Exchange Commission ("SEC") Division of Corporation Finance statement explains that "Covered Crypto Assets"—crypto tokens without any inherent rights to passive income, business enterprise...more
6/3/2025
/ Blockchain ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
Investment ,
New Guidance ,
Proposed Rules ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Regulation
The House Committees on Financial Services and Agriculture have unveiled a discussion draft for a new comprehensive U.S. crypto market structure bill, aiming to establish clear regulatory boundaries between the U.S....more
5/14/2025
/ Capital Raising ,
CFTC ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Financial Markets ,
Financial Regulatory Reform ,
Financial Services Committee ,
Financial Services Industry ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Reform ,
Securities Regulation ,
Stablecoins
The Federal Reserve Board ("Board") softened its stance on regulation of crypto activity by banking organizations by rescinding supervisory letters that created hurdles for crypto-asset activities and by joining the Office of...more
4/28/2025
/ Banks ,
Cryptocurrency ,
Digital Assets ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
FinTech ,
Investment ,
New Guidance ,
OCC ,
Regulatory Agencies ,
Regulatory Reform
As the Trump administration and Congress seek to establish clear digital asset regulation, uncertainty remains on whether federal agencies consider stablecoins to be "securities" under federal law....more
The FDIC has rescinded an earlier Financial Institution Letter establishing a prior notification requirement for FDIC-supervised institutions that wish to engage in specified crypto-related activities and has clarified that...more
4/3/2025
/ Banking Sector ,
Banks ,
Cryptocurrency ,
Deregulation ,
Digital Assets ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
New Guidance ,
OCC ,
Regulatory Reform ,
Regulatory Requirements ,
Rescission
As Congress moves to enact comprehensive stablecoin legislation under the Trump administration, both the Senate and the House of Representatives have updated their respective payment stablecoin bills. Our recent Commentary...more
3/18/2025
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Digital Assets ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Committee ,
Financial Services Industry ,
Financial Transactions ,
FinTech ,
Payment Systems ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Requirements ,
Stablecoins ,
U.S. Treasury
In recent years, U.S. federal bank regulators significantly limited banks' authority to engage in crypto-asset activities, including participating in public blockchains, owning digital assets as principal, and even providing...more
President Trump's recent executive order "Strengthening American Leadership in Digital Financial Technology" promoted the development of dollar-backed stablecoins as official U.S. policy. To facilitate this policy, Congress...more
3/3/2025
/ Cryptocurrency ,
Digital Assets ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
FinTech ,
OCC ,
Payment Systems ,
Proposed Legislation ,
Regulatory Agenda ,
Stablecoins ,
Trump Administration
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
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
The Financial Crimes Enforcement Network ("FinCEN") has issued a final rule ("Final Rule") extending the initial reporting deadline for new entities required to file beneficial ownership information ("BOI") with FinCEN to 90...more
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
2/15/2024
/ Bank Merger Act ,
Banks ,
BSA/AML ,
Community Reinvestment Act ,
Department of Justice (DOJ) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Global Systemically Important Banks (G-SIBs) ,
Merger Agreements ,
Merger Reviews ,
OCC ,
Policy Statement ,
Proposed Rules
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
1/11/2024
/ Banks ,
Climate Change ,
FDIC ,
Federal Reserve ,
Final Guidance ,
Financial Institutions ,
Financial Services Industry ,
Joint Statements ,
OCC ,
Risk Management ,
Supervisory Guidance
In Short -
The Situation: Over the course of 2023, the Financial Stability Oversight Council ("FSOC") took steps that increase the risk of nonbank financial companies and financial activities being designated as...more
The September 2023 publication by the U.S. Treasury Department of its Principles for Net-Zero Financing and Investment ("Principles") marks the first time a major U.S. government agency has provided guidance to the financial...more
12/4/2023
/ Banks ,
Climate Action Plan ,
Climate Change ,
Environmental Policies ,
Financial Institutions ,
Financial Regulatory Reform ,
Financing ,
Greenhouse Gas Emissions ,
Infrastructure ,
Investment ,
Net Zero ,
U.S. Treasury
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
10/19/2023
/ Banks ,
Borrowers ,
Debt ,
Debt Collection ,
Debt Instruments ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
Global Systemically Important Banks (G-SIBs) ,
Lenders ,
OCC ,
Proposed Rules ,
Subsidiaries
In Short -
The Situation: The Federal Deposit Insurance Corporation ("FDIC") has proposed significant amendments (the "Proposal") to its rule requiring covered insured depository institutions ("CIDIs") to prepare and file...more