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Federal Reserve › Banking Sector › Administrative Procedure Act

Cadwalader, Wickersham & Taft LLP

New Regulatory Priorities Spring Into Focus, April 2025 - Fed, FDIC and OCC Move to Rescind 2023 CRA Rule

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The Federal Deposit Insurance Corporation (“FDIC"), Federal Reserve Board (“FRB”), and the Office of the Comptroller of the Currency (“OCC”) (collectively, “the Agencies”) announced, that they intend to issue a proposal to...more

Davis Wright Tremaine LLP

"Operation Chokepoint 2.0": De-banking policies and the adverse use of reputational risk in bank supervision

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As we have previously noted, we expect that the second Trump Administration will be significantly more favorable to crypto than the Biden Administration, especially with the recent appointment of David Sacks as the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Supreme Court Opens the Door to More Rule Challenges by Extending Accrual Date for APA Cases

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In Corner Post v. Board of Governors of the Federal Reserve System, the U.S. Supreme Court held the six-year statute of limitations under 28 U.S.C. §2401 for challenging federal agency action under the Administrative...more

Venable LLP

Fintechs, Novel Charters, and Fed Master Accounts - Of Elephants and Mouseholes

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A U.S. District Court recently rejected arguments that banks and institutions with novel charters have a statutory right to obtain a Federal Reserve master account. Master accounts let institutions access key parts of the...more

Mayer Brown

Federal Reserve Wins Two Master Account Lawsuits

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At the end of March, components of the US Federal Reserve System (“FRS” or the “Fed”) prevailed in two lawsuits brought by depository institutions seeking master accounts.1 These decisions have significant implications for...more

Ballard Spahr LLP

NYDFS files brief with Second Circuit in OCC’s appeal from district court judgment in lawsuit challenging fintech charter

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The New York Department of Financial Services (DFS) has filed its opening brief with the Second Circuit in the OCC’s appeal from the district court’s final judgment in DFS’s lawsuit challenging the OCC’s issuance of special...more

Robins Kaplan LLP

Your Daily Dose of Financial News

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Breakingviews suggests that the devil is definitely in the details in Sempra Energy’s apparent winning bid for Oncor. Control of the company, for example, isn’t as simple as it might seem....more

Ballard Spahr LLP

D.C. District Court Allows Payday Lenders’ Due Process Claims To Proceed In Case Against “Operation Choke Point”

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On July 5, 2017, the U.S. District Court for the District Columbia, in the lawsuit filed in 2014 challenging “Operation Choke Point” — a federal enforcement initiative involving various agencies, including the Consumer...more

Katten Muchin Rosenman LLP

Six Federal Regulators Issue Final Interagency Policy Statement on Diversity Policies and Practices of Regulated Entities

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On June 9, the Federal Reserve Board, Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, National Credit Union Administration, Office of the Comptroller of the Currency and Securities and Exchange...more

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