News & Analysis as of

Office of the Comptroller of the Currency Banking Sector

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

Orrick, Herrington & Sutcliffe LLP

U.S. Senate banking committee requests extension for comment period on proposed leverage ratio rule

On August 8, several members of the U.S. Senate Committee on Banking, Housing, and Urban Affairs sent a letter to the heads of the Fed, the FDIC, and the OCC. The letter requested more rigorous data and analysis on the...more

Holland & Knight LLP

Executive Order Briefing: Guaranteeing Fair Banking for All Americans

Holland & Knight LLP on

President Donald Trump on Aug. 7, 2025, signed an executive order (EO or order) titled "Guaranteeing Fair Banking for All Americans," which declares that no American should be denied access to financial services based on...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

Davis Wright Tremaine LLP

FDIC Proposes to Bring Back Office of Supervisory Appeals

On July 18, 2025, the Federal Deposit Insurance Corporation (FDIC) released a proposal to amend its Guidelines for Appeals of Material Supervisory Determinations (Guidelines) to reinstate the Office of Supervisory Appeals...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

Orrick, Herrington & Sutcliffe LLP

FDIC and OCC release CRA evaluations for May and July of 2025, respectively

On August 5, the FDIC released its list of state nonmember banks evaluated for CRA compliance, covering ratings assigned in May 2025. The FDIC released the ratings of 69 institutions, with 63 receiving a satisfactory rating,...more

Orrick, Herrington & Sutcliffe LLP

White House Working Group on Digital Asset Markets releases report

On July 30, the president’s Working Group on Digital Asset Markets released a report setting out a coordinated federal approach to digital asset regulation. The report called for agencies to provide clearer guidance and...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

Bradley Arant Boult Cummings LLP

How Banks Can Harness New Customer ID Rule's Flexibility

Financial institutions across the U.S. have grappled with compliance requirements under the Customer Identification Program, or CIP, rule for more than two decades. On June 27, the Federal Deposit Insurance Corp., the...more

Nutter McClennen & Fish LLP

Nutter Bank Report: July 2025

In the wake of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), the federal banking agencies have issued joint guidance to provide clarity on supervisory expectations for banks that...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

Fenwick & West LLP

Congress Enacts Comprehensive Stablecoin Legislation: Key Provisions and Implications of the GENIUS Act

Fenwick & West LLP on

On July 18, President Donald Trump signed into law the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), creating the first federal framework for U.S. dollar stablecoins. ...more

Patomak Global Partners

American Bankers Association Conference Focused on AI

In June 2025, the ABA held its annual Risk and Compliance Conference. The conference heavily focused on how banks are leveraging AI to support front-, middle-, and back-office functions. Conference participants noted that...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

Sheppard Mullin Richter & Hampton LLP

Senate Confirms Jonathan Gould as Comptroller of the Currency

On July 10, 2025, the U.S. Senate confirmed Jonathan Gould as Comptroller of the Currency in a 50–45 vote. Gould will serve a five-year term and returns to the OCC, where he previously served as Chief Counsel and Senior...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

Vedder Price

OCC Ends Use of Disparate Impact in Fair Lending Supervision

Vedder Price on

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

Orrick, Herrington & Sutcliffe LLP

OCC’s new comptroller of the currency is Jonathan Gould

On July 15, the OCC announced that Jonathan V. Gould has taken office as the 32nd comptroller of the currency, following his nomination by President Donald J. Trump on February 11 and confirmation by the U.S. Senate on July...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

Skadden, Arps, Slate, Meagher & Flom LLP

The CIP Rule Gets an Upgrade: What Banks and Fintechs Need to Know About the New Exemption

Key Points - On June 27, 2025, the Federal Deposit Insurance Corporation (FDIC), the Office of Comptroller of the Currency (OCC) and the National Credit Union Administration (NCUA) exempted supervised banks and credit...more

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