News & Analysis as of

Office of the Comptroller of the Currency Banking Sector Trump Administration

Holland & Knight LLP

Executive Order Briefing: Guaranteeing Fair Banking for All Americans

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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

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

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

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

Sen. Warren pens letter against removing the enhanced supplementary leverage ratio for banks

On June 23, the Ranking Member of the U.S. Senate Committee on Banking, Housing, and Urban Affairs, Sen. Elizabeth Warren (D-MA), penned a letter raising concerns over reports that the Fed, the FDIC, and the OCC intended to...more

Orrick, Herrington & Sutcliffe LLP

President Trump signs law rescinding OCC rule on bank mergers

On June 20, President Trump signed into law S.J. Res. 13, which of the final rule submitted by the OCC titled “Business Combinations Under the Bank Merger Act.” As previously covered by InfoBytes, the OCC approved a final...more

Latham & Watkins LLP

OCC Bank Merger Rule Rescinded in Latest Regulatory Reversal

Latham & Watkins LLP on

The OCC is restoring its former practices and policies under the Bank Merger Act to reinstate expedited merger reviews and streamlined business combination applications....more

Goodwin

How Financial Regulation Is Shifting Under Trump

Goodwin on

Hi, thanks so much for joining us. I’m Samantha Kirby, chair of financial services here at Goodwin, and today, we’re going to talk to you about what we’re watching with respect to the bank regulatory agencies and the Consumer...more

Smith Anderson

From “Debanking” to Deregulation: A Turning Point for Reputational Risk

Smith Anderson on

Federal banking regulators are rapidly rewriting the playbook. In the early months of the second Trump administration, sweeping shifts in policy and supervisory priorities are already taking shape. One of the most...more

Latham & Watkins LLP

Federal Banking Agencies Plan to Rescind Community Reinvestment Act Final Rule

Latham & Watkins LLP on

In light of ongoing litigation and the Trump administration’s new policy approach, federal banking agencies intend to rescind the 2023 CRA final rule and revert to pre-2023 standards....more

Cooley LLP

FDIC: Banks Can Engage in Crypto-Related Activities Without Prior Notice

Cooley LLP on

On March 28, 2025, the Federal Deposit Insurance Corporation (FDIC) clarified that FDIC-supervised institutions do not need to provide notice or obtain approval from the FDIC prior to engaging in crypto-related activities....more

Latham & Watkins LLP

FDIC Removes Roadblocks to Crypto Activities in the Banking Sector

Latham & Watkins LLP on

New FDIC guidance permits crypto activities by supervised institutions without prior approval, emphasizing risk management and compliance with applicable laws and regulations....more

Moore & Van Allen PLLC

The Desk: March Edition

In other news from last month, we found out that Brian Quintenz was nominated by President Trump to serve as the next CFTC Chair. See our synopsis on Quintenz below. If and when Quintenz is confirmed—TBD on when the Senate...more

Vedder Price

Treasury Secretary Bessent Taps Rodney E. Hood to Lead the OCC

Vedder Price on

On February 10, 2025, Rodney E. Hood, the former Chairman of the National Credit Union Administration (“NCUA”), assumed the role of First Deputy Comptroller at the Office of the Comptroller of the Currency (the “OCC”). By...more

Troutman Pepper Locke

Treasury Secretary Bessent to Appoint Rodney E. Hood as First Deputy Comptroller of the OCC

Troutman Pepper Locke on

On February 7, Secretary of the Treasury Scott Bessent announced that he will appoint Rodney E. Hood as a Deputy Comptroller and designate him as the First Deputy Comptroller of the Office of the Comptroller of the Currency...more

Davis Wright Tremaine LLP

Acquiring or Investing in Banks – More Interest Expected in a Second Trump Administration

Federal banking agencies under a second Trump Administration are expected to be more receptive to industry proposals for bank mergers, acquisitions, and related transactions. We've previously explored national trust banks and...more

Davis Wright Tremaine LLP

Fintechs Branching Into the United States

The federal banking agencies under a second Trump Administration are expected to be more receptive to industry proposals geared toward growth. We've previously explored national trust banks to streamline state licensing....more

Latham & Watkins LLP

The Tides Are Changing (Again) for US “Fair Access” and “Anti-Debanking” Laws

Latham & Watkins LLP on

“Fair access” banking laws, at the epicenter of the debates between ESG and “anti-woke” regulation and federal/state preemption, may see a resurgence under the incoming administration. In recent years, the landscape of...more

Davis Wright Tremaine LLP

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

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

Goodwin

OCC Proposes Rescinding 2020 Amendments to CRA Regulation; Coordinated Agency Regulations Coming

Goodwin on

The Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency (OCC) released an interagency statement on July 20, 2021 that all three agencies will...more

Goodwin

OCC Delays Publication Of Trump Administration “Fair Access” Rule

Goodwin on

In this Issue. The Office of the Comptroller of the Currency (OCC) delayed publication of the “fair access” rule finalized late in the Trump Administration; the OCC also announced the availability of the 2021 list of bank...more

Goodwin

SEC Adopts Rule Providing New Regulatory Framework For Fund-Of-Funds

Goodwin on

In the News. The Securities and Exchange Commission (SEC) announced that it adopted Rule 12d1-4 under the Investment Company Act of 1940 (the 1940 Act), providing a new regulatory framework for fund-of-funds and final...more

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