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Financial Institutions Federal Reserve

Orrick, Herrington & Sutcliffe LLP

Fed withdraws its notice on supervising “novel activities”

On August 15, the Fed announced it withdrew its bank supervision program related to the Fed’s initiatives on “novel activities.” The Fed will return to monitoring banks’ novel activities through the normal supervisory...more

Cadwalader, Wickersham & Taft LLP

New Lessons in Regulation, August 2025 - FRB Rescinds Novel Activities Supervision Program and Vice Chair Bowman Speaks on...

Last week, (almost two years to the day of when it was issued), the Federal Reserve Board (“FRB”) rescinded SR Letter 23-7 regarding the creation of the Novel Activities Supervision Program. The FRB stated that supervision of...more

Troutman Pepper Locke

The Federal Reserve’s Shift in Supervision Strategy for Novel Activities

Troutman Pepper Locke on

On August 15, the Federal Reserve Board announced a significant shift in its approach to supervising novel activities within banking organizations. The Board decided to sunset its Novel Activities Supervision Program, which...more

Orrick, Herrington & Sutcliffe LLP

Senators pen letter to bank regulators on matters requiring attention

On August 6, the U.S. Senate Banking Committee sent a letter to the Fed’s Vice Chair for Supervision, Michelle Bowman, as well as Comptroller Jonathan Gould, and the FDIC’s Acting Chairman Travis Hill, urging them to address...more

Cooley LLP

Executive Order Guarantees Efforts Against Debanking Will Continue

Cooley LLP on

On Thursday, August 7, 2025, President Donald Trump signed an executive order (EO), “Guaranteeing Fair Banking Access for All Americans,” aimed at combatting “politicized or unlawful debanking.” Debanking generally refers to...more

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

Executive Order Calls for Crackdown on Politicized Debanking

Paul Hastings LLP on

On August 7, President Donald Trump signed the “Guaranteeing Fair Banking for All Americans” executive order (EO) directing federal banking regulators to investigate financial institutions that have restricted access to...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

Moore & Van Allen PLLC

Federal Reserve Board Hosts Capital Conference to Further Capital Reform Efforts

Moore & Van Allen PLLC on

On July 22, 2025, the Board of Governors of the Federal Reserve System (Board) hosted a first-of-its-kind industry conference designed to solicit public input on reform of the U.S. capital framework for financial...more

Orrick, Herrington & Sutcliffe LLP

Fed officials emphasize need for progress on financial inclusion

Recently, two members of the Fed, the Vice Chair for Supervision, Michelle Bowman, and Governor Michael Barr, both spoke on the ongoing challenges and opportunities in advancing financial inclusion across the U.S. Both...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

Morgan Lewis

Financial Institutions Face Investigations and Possible Referral to DOJ Based on Past ‘Debanking’ Practices

Morgan Lewis on

An executive order signed by the US president on August 7, 2025, titled Guaranteeing Fair Banking for All Americans, seeks to prohibit financial institutions from engaging in “debanking” practices, such as denying services or...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

Braumiller Law Group, PLLC

Hot Topics in International Trade - August 2025 - GENIUS Act Establishes Legal Framework for Payment Stablecoins

The President signed into law the Guiding and Establishing National Innovation for U.S. Stablecoins of 2025’or ‘‘GENIUS Act of 2025’” (the Act) on July 18, 2025. The new law establishes a basis for regulators to permit a...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

Davis Wright Tremaine LLP

Federal Banking Regulators Propose to Formally Flip Position on Biden-Era CRA Rules

In an expected move, the federal banking regulators issued a notice of proposed rulemaking (NPRM) to rescind Biden-era amendments to the 2023 regulations implementing the Community Reinvestment Act (CRA). The NPRM, issued by...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

Orrick, Herrington & Sutcliffe LLP

Stablecoin Framework Signed into Law

On July 18, 2025, the President signed the GENIUS Act into law, setting clear rules for who can issue payment stablecoins in the U.S. Only permitted issuers and registered foreign issuers are allowed, and they must follow...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

Wiley Rein LLP

Building a Digital Asset Regulatory Framework: The GENIUS Act and Next Steps

Wiley Rein LLP on

On July 18, President Trump signed into law the Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the GENIUS Act) establishing a regulatory framework for digital assets classified as payment...more

Mayer Brown

Federal Reserve Proposes Changes to Rating System for Large Financial Institutions

Mayer Brown on

On July 10, 2025, the Board of Governors of the Federal Reserve System (“Board”) proposed changes to its supervisory rating systems for large financial institutions (“LFIs”) and supervised insurance organizations (the...more

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