News & Analysis as of

Regulatory Oversight Office of the Comptroller of the Currency

Cozen O'Connor

Passage of the GENIUS Act: A Turning Point in Stablecoin and Digital Asset Regulation

Cozen O'Connor on

President Donald J. Trump has signed into law the GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins of 2025 or the GENIUS Act of 2025), establishing the first comprehensive federal framework for...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

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

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

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

Ballard Spahr LLP

Jonathan Gould confirmed as Comptroller of the Currency

Ballard Spahr LLP on

The Senate has confirmed Jonathan Gould as Comptroller of the Currency. Gould, who served as Senior Deputy Comptroller and Chief Counsel at the OCC during President Trump’s first term, was confirmed 50-45. Every Democrat...more

Orrick, Herrington & Sutcliffe LLP

OCC releases its CRA performance evaluations for June 2025

On July 1, the OCC released CRA performance evaluations for 22 national banks, federal savings associations, and insured federal branches of foreign banks, covering the period from June 1 through June 30. Of the evaluations...more

Orrick, Herrington & Sutcliffe LLP

House Oversight Committee sends letter to OCC’s Hood on debanking documents

On June 25, the Chairman for the House Committee on Oversight and Government Reform, Rep. James Comer (R-KY), sent a letter to OCC Acting Comptroller Rodney Hood requesting documents and communications related to the...more

Seward & Kissel LLP

GENIUS Move? Senate Passes Bill to Regulate Payment Stablecoins

Seward & Kissel LLP on

On June 17, 2025, the Senate voted 68-30 with bi-partisan support to pass the Guiding and Establishing National Innovation for U.S. Stablecoins Act (“GENIUS Act”), which proposes the establishment of a federal framework for...more

Pillsbury Winthrop Shaw Pittman LLP

The GENIUS Act: A New Federal Framework for Stablecoin Issuers

On June 18, 2025, the U.S. Senate passed the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). This passage followed a successful cloture vote earlier in May. The bill obtained significant...more

Orrick, Herrington & Sutcliffe LLP

OCC releases June 2025 enforcement actions

On June 18, the OCC announced enforcement actions against national banks, federal savings associations, and individuals currently or previously affiliated with supervised institutions. The OCC entered into three agreements...more

Sheppard Mullin Richter & Hampton LLP

OCC Enters Consent Orders Against New York-based Bank

On May 14, the OCC entered into a formal agreement with a New York-based bank after determining that the institution is in “troubled condition.” In its findings, the OCC cited alleged unsafe or unsound practices tied to the...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

Troutman Pepper Locke

Federal Banking Agencies Issue RFI on Payments and Check Fraud Mitigation Strategies

Troutman Pepper Locke on

On June 16, the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve Board, and the Office of the Comptroller of the Currency (OCC) issued a joint request for public comment on potential ways to address payments...more

Orrick, Herrington & Sutcliffe LLP

Prudential regulators issue RFI on payments fraud

On June 13, the OCC, the Fed, and the FDIC jointly issued an RFI seeking public input on ways to address rising payments fraud, with a particular emphasis on check fraud. The request for information seeks stakeholder feedback...more

Paul Hastings LLP

GENIUS Act Clears Senate, SEC Withdraws Proposed Rules and Bitcoin Reserve Bill Introduced

Paul Hastings LLP on

The Senate passed the GENIUS Act with bipartisan support, marking a significant step forward in advancing stablecoin legislation. Legislative action on stablecoins will now move to the House of Representatives. The House...more

Sheppard Mullin Richter & Hampton LLP

OCC Rejects Calls to Roll Back Preemption Rules

On June 9, Acting Comptroller of the Currency Rodney Hood issued a letter rejecting the Conference of State Bank Supervisors’ (CSBS) request that the OCC rescind its 2011 preemption regulations. The OCC ‘s letter signals...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

Orrick, Herrington & Sutcliffe LLP

OCC releases its May 2025 CRA performance evaluations

On June 2, the OCC released a list of CRA performance evaluations that became public during the month of May. The OCC evaluated 18 banking entities, including national banks, federal savings associations, and insured federal...more

Orrick, Herrington & Sutcliffe LLP

GAO pens letter to OCC’s Hood on outstanding recommendations

On May 15, the GAO penned a letter to the Acting Comptroller of the Currency, Rodney E. Hood, highlighting areas it believes warrant the OCC’s focus. First, the GAO recommended that the OCC establish policies and procedures...more

Fenwick & West LLP

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

Fenwick & West LLP on

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

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

Orrick, Herrington & Sutcliffe LLP

OCC releases May 2025 enforcement actions

On May 15, the OCC announced enforcement actions against two banks and three institution-affiliated parties. The OCC issued cease and desist orders to banks in Miami, as well as Beverly Hills, California, respectively, for...more

Patomak Global Partners

Fed Withdrawal of Guidance Marks Milestone for Banks’ Future Crypto Activity

The federal banking agencies have withdrawn previously issued guidance related to banks’ crypto activities, marking a shift in regulatory posture toward digital asset engagement. On April 25, the Federal Reserve Board...more

Sheppard Mullin Richter & Hampton LLP

OCC Confirms Banks Authority to Offer Crypto Custody and Execution Services

On May 7, the OCC issued Interpretive Letter 1184, reaffirming that national banks and federal savings associations may provide cryptocurrency custody and execution services, including through sub-custodians. The OCC...more

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