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Holland & Knight LLP

Executive Order Briefing: Guaranteeing Fair Banking for All Americans

Holland & Knight LLP on

President Donald Trump on Aug. 7, 2025, signed an executive order (EO or order) titled "Guaranteeing Fair Banking for All Americans," which declares that no American should be denied access to financial services based on...more

Bradley Arant Boult Cummings LLP

State Laws Show Uniformity Is Key To Truly Fair Bank Access

Over the past few years, one of the more noteworthy types of new financial services rules at the state level has been the so-called fair access to banking law. Concerns about ideological debanking have gained political...more

Paul Hastings LLP

Preparing Banks for the Next Round of Challenges While the Sun Is Still Shining

Paul Hastings LLP on

Fifteen years ago, in the shadow of the 2008 financial crisis, Congress adopted the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), the most significant change to financial regulation since the...more

Bradley Arant Boult Cummings LLP

President Trump Signs Debanking Executive Order: Horizontal Reviews for Banks and Credit Unions are Next

Late last year, we predicted that the Trump administration would bring federal action to target de-banking, and on August 7, 2025, President Trump signed a much-anticipated executive order to address the issue. Banks and...more

Orrick, Herrington & Sutcliffe LLP

Fed and FDIC release the public sections of 64 banks’ living wills

On August 5, the Fed and FDIC released the public sections of 2025 resolution plans for the eight largest and most complex domestic banking organizations and 56 foreign banking organizations. The plans, as required by the...more

Orrick, Herrington & Sutcliffe LLP

Fed issues report on the emergence of Pay-by-Bank

Recently, the Fed published a research note examining the rise of Pay-by-Bank as a payment solution for consumers, focusing on its adoption at the point of sale as an alternative to cash or credit payment options. The note...more

Ballard Spahr LLP

FDIC proposes to replace Supervision Appeals Review Committee with an independent office

Ballard Spahr LLP on

The FDIC is proposing to replace its Supervision Appeals Review Committee (SARC) with an independent, standalone office, known as the Office of Supervisory Appeals (OSA). Under the proposal, the OSA would be the final level...more

McGuireWoods LLP

Federal Banking Regulatory Agencies Issue Guidance on Crypto-Asset Safekeeping

McGuireWoods LLP on

The global crypto-asset market cap has increased from approximately $2.3 trillion on election day, November 5, 2024, to approximately $3.9 trillion today, some eight months later. That rise in demand has been accompanied by a...more

Morrison & Foerster LLP

Crypto-Asset Safekeeping: What’s Involved If You’re a Bank (or if You Want to Be One)

On July 14, 2025, the federal banking agencies issued a joint statement to clarify regulatory expectations for banking organizations that provide or are considering providing safekeeping for crypto-assets (“Joint Statement”)....more

Nutter McClennen & Fish LLP

The GENIUS Act is Signed into Law: What Banks Need to Know about Payment Stablecoins

On July 18, 2025, President Trump signed into law the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”), after it passed both the U.S. Senate by a vote of 68-30 and the U.S. House in a...more

Latham & Watkins LLP

Banking Agencies Issue Joint Statement on Risk-Management Considerations for Cryptoasset Safekeeping

Latham & Watkins LLP on

Banking organizations safekeeping digital assets for customers must do so in a safe and sound manner and in compliance with applicable laws and regulations....more

Sheppard Mullin Richter & Hampton LLP

Federal Banking Regulators Issue Joint Guidance on Crypto-Asset Safekeeping

On July 14, the OCC, Federal Reserve, and FDIC announced the release of a joint statement clarifying how existing laws and regulations apply to crypto-asset safekeeping services offered by banking organizations. The statement...more

Troutman Pepper Locke

Federal Agencies Release Guidance on Crypto-Asset Safekeeping for Banks

Troutman Pepper Locke on

On July 14, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (the Board), and the Federal Deposit Insurance Corporation (FDIC) jointly issued a statement addressing the...more

Cadwalader, Wickersham & Taft LLP

Midyear Momentum, July 2025 - Federal Reserve Releases Results of Stress Tests

On June 27, the Federal Reserve Board issued the aggregate and individual results of the supervisory stress test (also known as the Dodd-Frank Act Stress Test or DFAST, as these tests are required by Section 165 of the...more

Polsinelli

Federal Reserve Board Enforcement Action Raises Concerns as to Reach of Regulators’ Jurisdiction

Polsinelli on

Key Takeaways - The Federal Reserve Board issued a removal and prohibition order against a former bank employee based on alleged misconduct unrelated to her role at the bank, raising concerns about the scope of regulatory...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Capital Ratio Podcast | Entering the US Banking Market

When crafting an entry into the U.S. markets, U.K. and European financial institutions need to carefully plan an appropriate strategy. Sebastian Barling, host of “The Capital Ratio” is joined by financial institutions...more

Orrick, Herrington & Sutcliffe LLP

Fed releases annual stress test results for 2025

On June 27, the Fed released the results of its annual supervisory stress test, evaluating how large banks would perform under hypothetical adverse economic conditions. The Fed conducts stress tests annually as part of its...more

Orrick, Herrington & Sutcliffe LLP

Sen. Warren pens letter against removing the enhanced supplementary leverage ratio for banks

On June 23, the Ranking Member of the U.S. Senate Committee on Banking, Housing, and Urban Affairs, Sen. Elizabeth Warren (D-MA), penned a letter raising concerns over reports that the Fed, the FDIC, and the OCC intended to...more

Orrick, Herrington & Sutcliffe LLP

Fed announces that examination programs will no longer consider reputational risk

On June 23, the Fed announced it will no longer include reputational risk as a component of its examination programs in its supervision of banks. This move will align the Fed with the OCC, which made a similar announcement in...more

Perkins Coie

GENIUS Act Passes US Senate in Significant Step Towards Regulatory Clarity for Stablecoins

Perkins Coie on

The U.S. Senate passed the Guiding and Establishing National Innovation for U.S. Stablecoins Act or GENIUS Act (S.1582) (the Act) in a 68-30 bipartisan vote on June 17, 2025. The GENIUS Act would provide a clear regulatory...more

Sheppard Mullin Richter & Hampton LLP

Federal Reserve Board Removes Reputational Risk from Examination Ratings

On June 23, the Federal Reserve Board announced that reputational risk will no longer be a component of its bank-examination program. The same day, the Board released a revised edition of its Guidelines for Rating Risk...more

Kohrman Jackson & Krantz LLP

Federal Reserve Signals Shift Toward Pragmatic Banking Regulation

With a focus on pragmatic and risk-based oversight, new leadership at the Federal Reserve signals a shift in the regulatory landscape for U.S. banks. Earlier this month, the Senate confirmed Federal Reserve Governor Michelle...more

Orrick, Herrington & Sutcliffe LLP

District court receives amici request to participate in oral argument

On June 13, the U.S. District Court for the District of North Dakota received a motion from two amici curiae seeking leave to participate in oral arguments scheduled for July 23 on the parties’ cross motions for summary...more

Orrick, Herrington & Sutcliffe LLP

Fed Vice Chair for Supervision discusses using “pragmatism” in regulating banks safely

On June 6, the Fed’s Vice Chair for Supervision, Michelle Bowman, outlined her approach to enhance banking supervision and regulation during prepared remarks. In her remarks, Bowman emphasized using “pragmatism” to identify...more

Orrick, Herrington & Sutcliffe LLP

Bowman confirmed as Fed Vice Chair of Supervision

On June 4, the U.S. Senate voted to confirm Michelle Bowman as Vice Chair for Supervision of the Board of Governors of the Fed for a term of four years. President Trump planned to nominate Fed Governor Michelle Bowman as the...more

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