News & Analysis as of

Financial Institutions Federal Reserve Office of the Comptroller of the Currency

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

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

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

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

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

Smith Anderson

Feds' Shift On Reputational Risk Raises Questions For Banks

Smith Anderson on

In a significant shift, each of the country's three federal bank regulatory agencies have announced they will no longer consider reputational risk as a stand-alone supervisory category. Originally published in Law360 -...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

Vedder Price

OCC Ends Use of Disparate Impact in Fair Lending Supervision

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The Office of the Comptroller of the Currency (“OCC”) has formally revised its fair lending examination procedures, announcing in Bulletin 2025-16, issued on July 14, 2025, that it has eliminated all references to disparate...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

Orrick, Herrington & Sutcliffe LLP

Prudential regulators release statement on cryptocurrency safekeeping

On July 14, the OCC, the Fed, and the FDIC issued a joint statement addressing how existing laws, regulations and governing principles apply to banks which provide or are considering providing safekeeping for...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

Vedder Price

Jonathan Gould Confirmed as Comptroller of the Currency

Vedder Price on

On Thursday, July 10, 2025, the U.S. Senate confirmed Jonathan Gould to serve as the next Comptroller of the Currency in a 50–45 vote. Gould will succeed Acting Comptroller Rodney Hood, who offered his congratulations and...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

Ballard Spahr LLP

Federal banking agencies seek information on actions to address payments fraud

Ballard Spahr LLP on

On June 20, 2025, the Office of the Comptroller of the Currency (OCC), Treasury, the Board of Governors of the Federal Reserve System (FRB), and the Federal Deposit Insurance Corporation (FDIC) announced they are seeking...more

Orrick, Herrington & Sutcliffe LLP

Prudential regulators propose rule on bank capital requirements

On June 27, the OCC, the Fed, and the FDIC issued a notice of proposed rulemaking to revise the enhanced supplementary leverage ratio standards for U.S. global systemically important banks (GSIBs) and their subsidiaries. The...more

Nutter McClennen & Fish LLP

Nutter Bank Report: June 2025

The Federal Reserve has announced that the agency will no longer assess reputational risk when examining banks’ risk management processes. According to the June 23 announcement, the Federal Reserve has already begun reviewing...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

Perkins Coie

GENIUS Act Passes US Senate in Significant Step Towards Regulatory Clarity for Stablecoins

Perkins Coie on

The U.S. Senate passed the Guiding and Establishing National Innovation for U.S. Stablecoins Act or GENIUS Act (S.1582) (the Act) in a 68-30 bipartisan vote on June 17, 2025. The GENIUS Act would provide a clear regulatory...more

Sheppard Mullin Richter & Hampton LLP

Federal Reserve Board Removes Reputational Risk from Examination Ratings

On June 23, the Federal Reserve Board announced that reputational risk will no longer be a component of its bank-examination program. The same day, the Board released a revised edition of its Guidelines for Rating Risk...more

Ballard Spahr LLP

Fed to end use of reputational risk in examination programs

Ballard Spahr LLP on

The Federal Reserve Board has announced that it will eliminate reputational risk as a component of examination programs in its supervision of banks. ...more

Orrick, Herrington & Sutcliffe LLP

GAO Report Reveals How Financial Institutions (And Their Regulators) Are Using AI

Curious about how financial institutions, their service providers, and their federal regulators are using and overseeing machine learning and other AI tools? A new GAO report published on May 19th (the “Report”) provides a...more

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