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OCC Reverts to Prior Merger Rules

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

Reintroduction of Bill To Speed Up BHCA and HOLA Applications

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

Senate Moves To End "Operation Choke Point" De-Banking With New Bill—But More Protections Are Needed

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

OCC Rescinds Required Supervisory "Non-Objection" Preclearance for Permissible Crypto-Related Activities

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 The OCC has also rescinded a Biden-era...more

New Administration Outlook: Game Changer—Newly Revived Executive Order 13892 Expands Protections for Regulated Parties, For Now

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

Acquiring or Investing in Banks – More Interest Expected in a Second Trump Administration

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

Fintechs Branching Into the United States

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

"Operation Chokepoint 2.0": De-banking policies and the adverse use of reputational risk in bank supervision

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

DWT Attorneys File Amicus Brief in Support of Custodia Bank

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

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