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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

Ballard Spahr LLP

Trump issues Executive Order prohibiting ‘debanking’

Ballard Spahr LLP on

President Trump has issued an Executive Order directing banking agencies to adopt policies to ensure that financial institutions do not use reputational risk as a basis for restricting access to banking services—a process...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

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

Jones Day

Bank Merger and Acquisition Policy Changes: The Opportunity Is Now

Jones Day on

Banking agencies and the DOJ have signaled an openness to bank M&A where the combined institutions will enhance competition, customer benefits, technological innovation, and enterprise risk management....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

Cadwalader, Wickersham & Taft LLP

Global Moves, Digital Shifts, July 2025 - Fed, FDIC and OCC Issue Proposed Rulemaking to Rescind 2023 CRA Rule

Last week, the Federal Deposit Insurance Corporation (“FDIC), Federal Reserve Board (“FRB”), and the Office of the Comptroller of the Currency (“OCC”) (collectively, “the Agencies”)  issued a proposed rulemaking to both...more

Vedder Price

The GENIUS Act: Stablecoin Regulation Enters the Federal Framework

Vedder Price on

On July 18, 2025, President Trump signed the Guaranteed Essential National Infrastructure for U.S. Act (the “GENIUS Act”) into law, marking the first comprehensive U.S. federal regulatory framework for payment stablecoins. ...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

Cadwalader, Wickersham & Taft LLP

Global Moves, Digital Shifts, July 2025 - Federal Reserve Holds Large Bank Capital Framework Conference

On July 22nd, the Federal Reserve Board (“FRB”) hosted the Integrated Review of the Capital Framework for Large Banks Conference. The Conference appears to be a first of its kind for the FRB, and as Chair Jay Powell noted in...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

Davis Wright Tremaine LLP

Rethinking Bank Leverage and Capital Requirements in 2025

On July 10, 2025, the federal banking agencies published a proposed rule to change the enhanced supplementary leverage ratio (eSLR) for U.S. global systemically important bank holding companies (GSIBs) and their subsidiary...more

WilmerHale

What the GENIUS Act Means for Payment Stablecoin Issuers, Banks, and Custodians

WilmerHale on

The US House of Representatives has passed stablecoin legislation as part of “Crypto Week” on Capitol Hill. S. 1582, the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS or the Act), passed the US...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

Troutman Pepper Locke

Federal Banking Agencies Propose Rescission of 2023 CRA Final Rule and Reinstatement of 1995 CRA Regulations

Troutman Pepper Locke on

On July 16, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the federal banking agencies) jointly published a proposed rule...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

Orrick, Herrington & Sutcliffe LLP

Prudential regulators issue RFC on Call Report changes

On July 10, the OCC, the Fed, and the FDIC (the agencies) published a joint notice in the Federal Register for public comment on Call Report forms applicable to U.S. bank holding companies identified as global systemically...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Banking Regulators Propose Changes to the Enhanced Supplementary Leverage Ratio for US GSIBs

On June 27, 2025, the Federal Reserve approved a proposal to recalibrate a key capital requirement applicable to the largest U.S. banking organizations (known as global systemically important banks (GSIBs)). - The proposal...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

Coblentz Patch Duffy & Bass

Federal Reserve to Implement New ISO 20022 Funds Wiring System

Due to the Federal Reserve’s imminent shift to a new funds wiring system (known as ISO 20022), if you have upcoming plans to transfer any amount of funds via wire transfer, confirm with your bank and anyone else handling your...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

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

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