On July 18, 2025, the Federal Deposit Insurance Corporation (FDIC) released a proposal to amend its Guidelines for Appeals of Material Supervisory Determinations (Guidelines) to reinstate the Office of Supervisory Appeals...more
We noted last week in connection with our initial post regarding the Presidential Working Group Report on Digital Assets (the "PWG Report" or the "Report") that we would be engaged in further analysis of that Report and offer...more
In an expected move, the federal banking regulators issued a notice of proposed rulemaking (NPRM) to rescind Biden-era amendments to the 2023 regulations implementing the Community Reinvestment Act (CRA). The NPRM, issued by...more
7/29/2025
/ Banking Sector ,
Biden Administration ,
Compliance ,
CRA ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
Loans ,
Notice of Proposed Rulemaking (NOPR) ,
Proposed Rules ,
Regulatory Reform
Industrial banks or industrial loan companies (ILCs)—FDIC-insured banks chartered by certain states, notably Utah—have long been a niche component of the U.S. financial system. These institutions may be owned by commercial...more
7/25/2025
/ Bank Holding Company Act ,
Banking Sector ,
Banks ,
FDIC ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Lenders ,
Regulatory Reform ,
Regulatory Requirements ,
Risk Management
On July 15, 2025, the Federal Reserve Board released a proposed rule to revise the Large Financial Institution rating system or "LFI Framework." The proposal would change how the Fed evaluates the financial and managerial...more
On July 5, 2025, the FDIC finalized (and published in the Federal Register) its decision to rescind its 2024 Bank Merger Statement of Policy and reinstate its prior, long-standing version. We previously covered the proposed...more
The Office of the Comptroller of the Currency (OCC) has issued an interim final rule that restores streamlined and expedited regulatory procedures to review applications under the Bank Merger Act for business combinations...more
The Trump Administration has made clear that it intends to lessen the barriers to bank merger and acquisition activity. As we previously noted, the FDIC has moved to lower some of the impediments to mergers under its 2024...more
Following a key hearing in February, Senate Banking Committee Chairman Tim Scott (R-SC) is seeking to protect financial freedom with the introduction of the Financial Integrity and Regulation Management (FIRM) Act. The...more
3/13/2025
/ Banking Sector ,
Cryptocurrency ,
Due Process ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
NCUA ,
OCC ,
Proposed Legislation ,
Regulatory Reform ,
Senate Committees
The OCC has reiterated that certain crypto-related activities—crypto-asset custody, distributed ledger, and stablecoin activities—previously determined to be permissible remain so. The OCC has also rescinded a Biden-era...more
The recent confirmation of Russ Vought as director of the Office of Management and Budget (OMB) is expected to kickstart the Administration's centralized approach to reforming the administrative state. The recently revived...more
Federal banking agencies under a second Trump Administration are expected to be more receptive to industry proposals for bank mergers, acquisitions, and related transactions. We've previously explored national trust banks and...more
1/17/2025
/ Acquisitions ,
Bank Holding Company Act ,
Bank Merger Act ,
Banking Sector ,
CBCA ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Foreign Banks ,
Investment ,
Investors ,
Mergers ,
OCC ,
Regulatory Agenda ,
Trump Administration
The federal banking agencies under a second Trump Administration are expected to be more receptive to industry proposals geared toward growth. We've previously explored national trust banks to streamline state licensing....more
1/10/2025
/ Banking Sector ,
Banks ,
Compliance ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
FinTech ,
Foreign Investment ,
OCC ,
Regulatory Agenda ,
Trump Administration
As we have previously noted, we expect that the second Trump Administration will be significantly more favorable to crypto than the Biden Administration, especially with the recent appointment of David Sacks as the...more
12/9/2024
/ Accounting Standards ,
Administrative Procedure Act ,
Anti-Money Laundering ,
Banking Sector ,
Confidential Supervisory Information ,
Cryptocurrency ,
Digital Assets ,
FDIC ,
Federal Reserve ,
Innovation ,
OCC ,
Operation Choke Point ,
Policies and Procedures ,
Reputational Injury ,
Risk Assessment ,
Transparency ,
Trump Administration
DWT attorneys recently filed an amicus brief on behalf of the co-chairs of the Wyoming Select Committee on Blockchain Technology in support of the application of Custodia Bank (which is a Special Purpose Depository...more