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Federal Banking Regulators Propose to Formally Flip Position on Biden-Era CRA Rules

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

FDIC Rethinks Industrial Banks—Again

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

FDIC Finalizes Return to Long-standing Bank Merger Policy

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

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

New Administration Outlook: An Opening for a National Payments/Fintech Charter – and a Pathway to Financial Modernization?

Recent announcements by Trump Media and Technology Group (TMTG) and X might signal that financial modernization may have finally reached a tipping point. With the right regulatory environment, fintechs and other new market...more

What Could a "Strategic Bitcoin Reserve" Mean in Practice?

The United States is no stranger to stockpiling strategic assets to serve important national interests. The U.S. strategic gold reserve provides financial stability and supports the value of the U.S. dollar...more

National Trust Banks – Revisited for Crypto and Payments

In the absence of modern charters and licenses, payments companies and other fintechs—both established financial services providers and new market entrants—must generally obtain 50+ money transmitter and possibly other state...more

Bank Regulatory Considerations in a Second Trump Administration – What Could Change, What Could Stay the Same

While the coming weeks and months will provide more clarity, we already can anticipate some indications of what is in store for bank regulation, supervision, and enforcement in a second Trump Administration. To help navigate...more

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