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Digital Assets Federal Deposit Insurance Corporation Risk Management

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 Banking Regulators on Crypto-Asset Safekeeping

Just days prior to the passage of the GENIUS Act on stablecoins by Congress, on July 14th, the Federal Reserve, Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (collectively, the...more

Latham & Watkins LLP

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

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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

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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

Jones Day

Banking on Crypto: Regulators Clarify Rules for Digital Asset Safekeeping

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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

Troutman Pepper Locke

FOIA Litigation Unveils Important Supervisory Insights and Needed Reform

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Following the Freedom of Information Act (FOIA) litigation brought against the Federal Deposit Insurance Corporation (FDIC) in 2024, on February 5, 2025, the FDIC released hundreds of pages of documents related to its...more

Patomak Global Partners

Fed Withdrawal of Guidance Marks Milestone for Banks’ Future Crypto Activity

The federal banking agencies have withdrawn previously issued guidance related to banks’ crypto activities, marking a shift in regulatory posture toward digital asset engagement. On April 25, the Federal Reserve Board...more

Ballard Spahr LLP

OCC, FDIC eliminating ‘reputational risk’ from supervision, examinations

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The OCC has removed “reputational risk” from its handbooks and guidance and the FDIC is moving to do the same. ...more

Patomak Global Partners

FDIC Highlights Policy Priorities Impacting FinTechs and Large Banks

In April 2025, Federal Deposit Insurance Corporation (FDIC) Acting Chairman Travis Hill announced that the FDIC is focused on four key policy areas: de novo bank formation, digital assets and blockchain activities, resolution...more

Sheppard Mullin Richter & Hampton LLP

FDIC Updates Crypto Guidance, Removes Pre-Approval Requirement for Banks

On March 28, the FDIC issued updated guidance clarifying the process for FDIC-supervised institutions to engage in crypto-related activities. The guidance rescinds and replaces prior instructions issued in 2022 and makes...more

Orrick, Herrington & Sutcliffe LLP

FDIC no longer requires notification of crypto-related activities

On March 28, the FDIC announced new guidance allowing FDIC-supervised institutions to engage in permissible crypto-related activities without prior approval. This update, outlined in FIL-7-2025, rescinded the previous...more

Sheppard Mullin Richter & Hampton LLP

FDIC Aims to Eliminate Reputational Risk from Supervision

On March 24, acting FDIC Chairman Travis Hill informed Congress that the agency is preparing to eliminate the use of “reputation risk” as a basis for supervisory criticism. In a letter to Rep. Dan Meuser (R-Pa.), Hill...more

Wilson Sonsini Goodrich & Rosati

A Crypto-Friendly Pivot in Bank Supervision: Three Practical Action Items for Innovators

A federal banking agency, the Office of the Comptroller of the Currency (OCC), has smoothed the way for national banks and federal savings associations to engage in crypto-related activities with the issuance of Interpretive...more

Kilpatrick

Roadmap for Changes to Bank Regulation Under the Trump Administration Begins to Emerge

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While the Trump Administration’s approach to bank regulation has been the subject of much speculation, specific proposals have yet to emerge, and the administration has yet to name key personnel in the regulatory agencies. ...more

Troutman Pepper Locke

FDIC Acting Chairman Hill Outlines Near-Term Policy Direction

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On January 20, Travis Hill became the Acting Chairman of the Federal Deposit Insurance Corporation (FDIC). Following his remarks on FDIC policy issues on January 10 at the American Bankers Association, in his first statement...more

Paul Hastings LLP

PHFintech: Crypto Policy Tracker - December 13, 2024

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A significant headwind for companies in the digital asset space is that they have reportedly struggled to secure and maintain relationships with banks, in what is now called “Choke Point 2.0.” With the incoming Trump...more

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter - August 2024 # 3

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Foodman CPAs & Advisors

La Revisión De Riesgos De La FDIC 2023 Agrega El Cripto

El 14/08/23 se publicó la Revisión de Riesgos de la FDIC 2023. El informe “FDIC Risk Review 2023” resume las condiciones de la economía, los mercados financieros y la industria bancaria de los EE. UU. El informe proporciona...more

Foodman CPAs & Advisors

FDIC Risk Review 2023 Adds Crypto

On 8/14/23, the FDIC Risk Review 2023 was published. The FDIC Risk Review 2023 report summarizes conditions in the U.S. economy, financial markets, and banking industry. The report provides a comprehensive summary of key...more

Cadwalader, Wickersham & Taft LLP

FDIC's Annual Risk Review Includes Crypto Risks for First Time

The Federal Deposit Insurance Corporation (“FDIC”) published its annual Risk Review this past Monday, providing an overview of banking conditions for 2022 through early 2023. The FDIC started providing Risk Reviews to the...more

Orrick, Herrington & Sutcliffe LLP

Agencies warn banks of crypto-asset liquidity risks

On February 23, the FDIC, Federal Reserve Board, and OCC released a joint statement addressing bank liquidity risks tied to crypto-assets. The agencies warned that using sources of funding from crypto-asset-related entities...more

Proskauer - Blockchain and the Law

Custodia Bank Is, Once Again, Asking for a Federal Reserve Master Account

On December 12, 2022, Custodia Bank (“Custodia”) – a state-chartered, digital asset-focused bank based in Wyoming – was denied its motion for a default judgment in its battle with the Federal Reserve Board of Governors (the...more

Goodwin

CFPB Launches New Initiative Focused on Rural Communities

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In This Issue. The Consumer Financial Protection Bureau (CFPB) announced a new initiative focused on financial issues faced by rural communities and also updated its examination procedures to cover unfair discrimination; the...more

Goodwin

FinCEN Warns Against Evasion of Russian Sanctions

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In this Issue. The Financial Crimes Enforcement Network (FinCEN) published an alert warning financial institutions of possible efforts to evade U.S.-imposed sanctions on Russia and Belarus; the U.S. Department of the Treasury...more

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