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On July 15, 2025, the Federal Deposit Insurance Corporation (“FDIC”) requested comment on its framework for reviewing applications for deposit insurance from industrial loan companies and industrial banks (collectively,...more
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
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
On July 18, 2025, President Trump signed into law the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”), establishing the first U.S. statutory federal regulatory framework for payment...more
In a significant shift, each of the country's three federal bank regulatory agencies have announced they will no longer consider reputational risk as a stand-alone supervisory category. Originally published in Law360 -...more
Today marks a historic milestone in U.S. digital asset policy. The President signed the GENIUS Act into law following its bipartisan passage by 308-122 in the House on July 17 and 68-30 in the Senate on June 17. The GENIUS...more
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
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
On July 15, the FDIC Board approved the publication of a request for information on how the FDIC should review filings submitted by industrial banks and industrial loan companies....more
On July 15, the FDIC Board withdrew a proposed rule concerning the oversight of parent companies of industrial banks and industrial loan companies. The withdrawal means the FDIC no longer intends to issue a final rule on...more
On July 15, the FDIC Board approved a proposal to amend the FDIC’s Guidelines for Appeals of Material Supervisory Determinations by replacing the existing Supervision Appeals Review Committee with an independent office within...more
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
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
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
On June 27, the OCC, the Fed, and the FDIC issued a notice of proposed rulemaking to revise the enhanced supplementary leverage ratio standards for U.S. global systemically important banks (GSIBs) and their subsidiaries. The...more
The Federal Reserve, alongside the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC), released their highly anticipated Notice of Proposed Rulemaking to overhaul the Enhanced...more
Last week, the US federal banking regulators proposed changes to the enhanced supplementary leverage ratio (“eSLR”) requirement for US global systemically important bank holding companies (“US GSIBs”) (the “Proposal”)....more
The Federal Reserve has announced that the agency will no longer assess reputational risk when examining banks’ risk management processes. According to the June 23 announcement, the Federal Reserve has already begun reviewing...more
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
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
This week, the Federal Reserve Board (“FRB") and the Office of the Comptroller of the Currency (“OCC”) issued a notice of proposed rulemaking (“NPR") to amend the Enhanced Supplementary Leverage Ratio (“eSLR”). At the time of...more
On June 13, the OCC, the Fed, and the FDIC jointly issued an RFI seeking public input on ways to address rising payments fraud, with a particular emphasis on check fraud. The request for information seeks stakeholder feedback...more
On June 16, the U.S. Supreme Court denied a bank holding company’s petition for certiorari after the Tenth Circuit upheld summary judgment in a bank receivership matter that was granted by a lower court in favor of the State...more
Mergers and acquisitions continue to be a critical strategy for banks aiming to bolster their market presence and operational efficiency. The United States has 4,500+ banks, 4,000+ credit unions, and a large number of...more
On June 5, the FDIC released an updated list of state nonmember banks that received CRA evaluation ratings assigned in March 2025. The CRA mandates that the FDIC assess and rate how well banks meet the credit needs of their...more