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
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
The FDIC has rescinded an earlier Financial Institution Letter establishing a prior notification requirement for FDIC-supervised institutions that wish to engage in specified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
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
An estimated 32.6 million domestic and foreign companies will soon be required to report information about their beneficial owners to the U.S. Treasury. This White Paper describes the new requirements and the steps companies...more
In Short -
The Situation: The federal banking agencies approved a proposal that would implement a "gold-plated" U.S. version of the "Basel III endgame."...more
In Short -
The Situation: The Financial Stability Oversight Council ("FSOC") recently issued a "notification of proposed interpretive guidance" on updated procedures for designating nonbank financial companies as...more
In Short -
The Background: The recent failure of Silicon Valley Bank, the second-largest bank failure in U.S. history, temporarily paralyzed start-ups, public companies, venture firms, private equity firms, and portfolio...more
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
On September 29, 2022, the Board of Governors of the Federal Reserve System ("Fed") announced that six of the largest U.S. banks will participate in a first-of-its-kind climate scenario analysis program. The Fed will provide...more