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Office of the Comptroller of the Currency FinTech Risk Management

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

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

Orrick, Herrington & Sutcliffe LLP

OCC’s Hood remarks on building a “resurgent” financial system

On June 3, the OCC Acting Comptroller, Rodney E. Hood, delivered remarks outlining how he plans to build a resilient and resurgent financial system. The Acting Comptroller emphasized four key strategies: accelerating...more

Goodwin

Acting Comptroller of the Currency Discusses OCC’s Regulatory Agenda

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In recent remarks delivered at the U.S. Chamber of Commerce Capital Markets Summit, Acting Comptroller of the Currency, Rodney E. Hood, outlined the OCC’s strategic priorities for building a resilient and revitalized federal...more

Fenwick & West LLP

Bank-Fintech Partnerships Under Scrutiny: What Fintechs Need to Know About AML Expectations

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Bank-fintech partnerships have transformed the financial services landscape, creating new opportunities and challenges for traditional banking institutions and innovative technology companies alike. In a typical arrangement,...more

Orrick, Herrington & Sutcliffe LLP

OCC requests information on banks’ digitalization efforts

On May 5, the OCC released a request for information (RFI) seeking public comment on community banks’ efforts towards digitalization. The OCC stated this RFI will enhance its supervisory activities. The OCC aims to understand...more

Sheppard Mullin Richter & Hampton LLP

OCC’s Hood Emphasized AI Oversight and Inclusion in Financial Services

On April 29, Acting Comptroller of the Currency Rodney Hood delivered pre-recorded remarks at the National Fair Housing Alliance’s Responsible AI Symposium.  In his speech, Hood reiterated the OCC’s commitment to deploying AI...more

Orrick, Herrington & Sutcliffe LLP

OCC’s Hood emphasizes responsible AI use for financial inclusion

On April 29, Rodney E. Hood, Acting Comptroller of the Currency, delivered a speech for the National Fair Housing Alliance’s Responsible AI Symposium. In his remarks, Hood emphasized the importance of financial inclusion and...more

Smith Anderson

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

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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

FDIC Removes Roadblocks to Crypto Activities in the Banking Sector

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

Troutman Pepper Locke

Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast

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In this episode of Payments Pros, host Carlin McCrory discusses a recent consent order between Patriot Bank and the Office of the Comptroller of the Currency (OCC) following a $27 million loss. The order addresses unsafe...more

Sheppard Mullin Richter & Hampton LLP

OCC Signals Shift on Crypto and Debanking Under Acting Comptroller Hood 

On March 18, Acting Comptroller of the Currency Rodney Hood reiterated the OCC’s commitment to ensuring fair access to banking services, including for cryptocurrency firms. Speaking at a retail banking industry conference,...more

Orrick, Herrington & Sutcliffe LLP

OCC conditionally grants bank’s application for fintech purchase

On March 17, the OCC announced it had conditionally approved an application of a fintech to change the business model of a nationally chartered bank upon acquisition of the bank by the fintech, specifically allowing the...more

Ballard Spahr LLP

Crypto Clarity: OCC’s New Guidelines Pave the Way for Banking Innovation

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On March 7, 2025, the Office of the Comptroller of the Currency (“OCC”) released Interpretive Letter 1183, marking a pivotal change in regulatory guidance for national banks and federal savings associations engaging in...more

Wilson Sonsini Goodrich & Rosati

A Crypto-Friendly Pivot in Bank Supervision: Three Practical Action Items for Innovators

A federal banking agency, the Office of the Comptroller of the Currency (OCC), has smoothed the way for national banks and federal savings associations to engage in crypto-related activities with the issuance of Interpretive...more

Troutman Pepper Locke

OCC Clarifies Bank Authority to Engage in Certain Cryptocurrency Activities

Troutman Pepper Locke on

On March 7, the Office of the Comptroller of the Currency (OCC) issued a significant update regarding the involvement of national banks and federal savings associations in cryptocurrency activities. Interpretive Letter 1183...more

Davis Wright Tremaine LLP

OCC Rescinds Required Supervisory "Non-Objection" Preclearance for Permissible Crypto-Related Activities

The OCC has reiterated that certain crypto-related activities—crypto-asset custody, distributed ledger, and stablecoin activities—previously determined to be permissible remain so. The OCC has also rescinded a Biden-era...more

Latham & Watkins LLP

Competing Stablecoin Bills Reflect Consensus and Divergence on Key Issues

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Stablecoin regulation is a top priority for lawmakers, and three recent proposals reflect differing perspectives on how to achieve regulatory clarity while balancing safety and innovation....more

Paul Hastings LLP

PHFintech: Crypto Policy Tracker - December 13, 2024

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A significant headwind for companies in the digital asset space is that they have reportedly struggled to secure and maintain relationships with banks, in what is now called “Choke Point 2.0.” With the incoming Trump...more

Cadwalader, Wickersham & Taft LLP

Banking Regulators’ Request for Information on Bank-Fintech Arrangements

On July 25, 2024, the Fed, the OCC and the FDIC (the “Banking Regulators”) released a “Request for Information on Bank-Fintech Arrangements Involving Banking Products and Services Distributed to Consumers and Businesses” (the...more

Morrison & Foerster LLP

Banking Agencies Address Banking Arrangements with Third Parties to Provide Deposit Products and Services

On July 25, 2024, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint statement to banks regarding risks...more

Ballard Spahr LLP

Bank Regulators Issue Statement on Third-Party Relationships with Financial Institutions and Publish Request for Information on...

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The federal banking regulators (The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation) issued on July 25 a lengthy joint statement...more

Ballard Spahr LLP

Banking Regulators Seek Comment on Third-Party Relationships with Financial Institutions

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The federal banking regulators are seeking comment to better understand the relationship between financial institutions and third parties that work for them....more

Troutman Pepper Locke

Federal Banking Agencies Reiterate Guidance on Managing Risks Posed By Fintech Partnerships and Other Third Party Relationships

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Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more

Goodwin

10 Considerations for Fintechs Partnering with Community Banks

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As banking and technology become more integrated, banks are increasingly partnering with fintechs to expand their customer offerings. The rapid rise of these partnerships has generated questions for both banks and fintechs on...more

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