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Federal banking regulators continue to promote a more "crypto-positive" regulatory environment through recent joint guidance issued to clarify risk management and compliance expectations for banks providing crypto-asset...more
The FDIC and OCC have rescinded policy statements adopted in 2024 that changed the ways each agency considered bank merger transactions and have reinstated their prior procedures for evaluating bank mergers. The FDIC on May...more
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
On May 7, the OCC issued Interpretive Letter 1184, reaffirming that national banks and federal savings associations may provide cryptocurrency custody and execution services, including through sub-custodians. The OCC...more
This regular publication from DLA Piper focuses on helping banking and financial services clients navigate the ever-changing regulatory landscape....more
The federal banking regulators have each recently adopted a more permissive approach to the regulation of cryptocurrency activities within the banking sector. The Office of the Comptroller of the Currency (OCC), the Federal...more
On March 6, President Trump issued an Executive Order establishing a Strategic Bitcoin Reserve capitalized by Government BTC and a U.S. Digital Asset Stockpile capitalized by other crypto assets. Creating the Strategic...more
On March 7, the OCC issued its Interpretive Letter 1183, affirming that national banks and federal savings associations can engage in various cryptocurrency activities, including crypto-asset custody, certain stablecoin...more
On March 7, the Office of the Comptroller of the Currency (OCC) issued a significant update regarding the involvement of national banks and federal savings associations in cryptocurrency activities. Interpretive Letter 1183...more
In recent years, U.S. federal bank regulators significantly limited banks' authority to engage in crypto-asset activities, including participating in public blockchains, owning digital assets as principal, and even providing...more
In 2023, the digital asset industry demonstrated remarkable resilience amidst significant challenges, including the dissolution of several digital asset financial services companies, numerous bank failures, and a $4.7 billion...more
Earlier this month, the Federal Reserve Board (FRB) released two supervision and regulation letters regarding the agency’s program to supervise “novel” banking activities....more
In this most recent issue, we discuss a number of federal banking agency updates, including the long-awaited Final Interagency Guidance on Third-Party Relationships and the Federal Reserve Bank of New York’s report on the...more
On June 6, 2023, federal banking agencies issued final Interagency Guidelines on Third-Party Relationships detailing their expectations for banks in establishing risk management practices with third-parties—including...more
On June 6, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Federal Reserve), and the Federal Deposit Insurance Corporation (FDIC) (collectively, the Banking Agencies)...more
On February 23, The Board of Governors of the Federal Reserve System (the Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the Agencies) issued a...more
Earlier yesterday, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”) issued a “Joint Statement on Liquidity Risks to Banking Organizations...more
The last few years had started to see a convergence between crypto and banking, with bitcoin appearing to rapidly grow mainstream. That momentum hit a wall with the spectacular crypto market failures of 2022, including the...more
In the past year, the Board of Governors of the Federal Reserve System (the Board) Biden administration officials, and other U.S. banking regulators have repeatedly voiced growing concerns about certain cryptoasset...more
The Federal Deposit Insurance Act (FDIA) generally prohibits insured state banks, but not uninsured state member banks, from acting as principal in activities that are not permissible for national banks. Relying on its...more
On January 3, the FDIC, Federal Reserve Board, and OCC issued a joint interagency statement highlighting key risks banks should consider when choosing to engage in cryptocurrency-related services. ...more
On January 3, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) issued a Joint Statement on...more
On January 3, The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (the Agencies) issued a joint statement to banking organizations...more
The Federal Reserve Board, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency have issued a joint statement on crypto-asset risks to banking organizations. The term “crypto-asset” refers...more
Federal Banking Agencies Publish Policy Road Map for Crypto-Asset Activities - The federal banking agencies have issued a joint statement summarizing their interagency “policy sprints” focused on crypto-asset activities...more