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Banking Sector Banks Office of the Comptroller of the Currency

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

Orrick, Herrington & Sutcliffe LLP

FDIC and OCC release CRA evaluations for May and July of 2025, respectively

On August 5, the FDIC released its list of state nonmember banks evaluated for CRA compliance, covering ratings assigned in May 2025. The FDIC released the ratings of 69 institutions, with 63 receiving a satisfactory rating,...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

Patomak Global Partners

American Bankers Association Conference Focused on AI

In June 2025, the ABA held its annual Risk and Compliance Conference. The conference heavily focused on how banks are leveraging AI to support front-, middle-, and back-office functions. Conference participants noted that...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

Skadden, Arps, Slate, Meagher & Flom LLP

The CIP Rule Gets an Upgrade: What Banks and Fintechs Need to Know About the New Exemption

Key Points - On June 27, 2025, the Federal Deposit Insurance Corporation (FDIC), the Office of Comptroller of the Currency (OCC) and the National Credit Union Administration (NCUA) exempted supervised banks and credit...more

Orrick, Herrington & Sutcliffe LLP

OCC releases June 2025 enforcement actions

On June 18, the OCC announced enforcement actions against national banks, federal savings associations, and individuals currently or previously affiliated with supervised institutions. The OCC entered into three agreements...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

Sheppard Mullin Richter & Hampton LLP

OCC Enters Consent Orders Against New York-based Bank

On May 14, the OCC entered into a formal agreement with a New York-based bank after determining that the institution is in “troubled condition.” In its findings, the OCC cited alleged unsafe or unsound practices tied to the...more

McGuireWoods LLP

OCC Reaffirms that its National Bank Preemption Regulations are Lawful

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On May 8, 2025, the Conference of State Bank Supervisors (“CSBS”) asked the Office of the Comptroller of the Currency (“OCC”) to comply with Executive Orders 14129 and 14267 by reversing its regulations governing national...more

Orrick, Herrington & Sutcliffe LLP

OCC responds to association’s letter to rescind its preemption regulations

On June 9, the OCC rejected a request from a group of state bank supervisors to rescind its preemption regulations, affirming its position that its rules align with federal law, Supreme Court precedent, and recent executive...more

Sheppard Mullin Richter & Hampton LLP

OCC Rejects Calls to Roll Back Preemption Rules

On June 9, Acting Comptroller of the Currency Rodney Hood issued a letter rejecting the Conference of State Bank Supervisors’ (CSBS) request that the OCC rescind its 2011 preemption regulations. The OCC ‘s letter signals...more

Orrick, Herrington & Sutcliffe LLP

OCC’s Hood remarks on building a “resurgent” financial system

On June 3, the OCC Acting Comptroller, Rodney E. Hood, delivered remarks outlining how he plans to build a resilient and resurgent financial system. The Acting Comptroller emphasized four key strategies: accelerating...more

Orrick, Herrington & Sutcliffe LLP

OCC releases its May 2025 CRA performance evaluations

On June 2, the OCC released a list of CRA performance evaluations that became public during the month of May. The OCC evaluated 18 banking entities, including national banks, federal savings associations, and insured federal...more

Goodwin

Acting Comptroller of the Currency Discusses OCC’s Regulatory Agenda

Goodwin on

In recent remarks delivered at the U.S. Chamber of Commerce Capital Markets Summit, Acting Comptroller of the Currency, Rodney E. Hood, outlined the OCC’s strategic priorities for building a resilient and revitalized federal...more

Orrick, Herrington & Sutcliffe LLP

OCC releases semiannual Interest Rate Risk Statistics Report

Recently, the OCC released its Spring 2025 Interest Rate Risk Statistics Report detailing interest rate risk data gathered during examinations of OCC-supervised midsize and community banks and federal savings associations....more

Orrick, Herrington & Sutcliffe LLP

Acting Comptroller discusses importance of financial inclusion

On May 8, Acting Comptroller of the Currency Rodney E. Hood spoke on his four priority areas: financial inclusion, reducing regulatory burdens, bank-fintech partnerships, and digital assets. He emphasized that financial...more

Orrick, Herrington & Sutcliffe LLP

OCC clarifies crypto-asset activities in interpretive letter

On May 7, the OCC clarified permissible activities for national banks and federal savings associations regarding crypto-asset custody and execution services by publishing Interpretive Letter 1184. This letter confirmed...more

Goodwin

Regulatory Process for Forming or Acquiring a Depository Institution

Goodwin on

This third installment in our series of insights on bank charter considerations describes the process for seeking regulatory approval to form or acquire a bank....more

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