News & Analysis as of

Regulatory Oversight Office of the Comptroller of the Currency Banks

Troutman Pepper Locke

Federal Banking Agencies Propose Rescission of 2023 CRA Final Rule and Reinstatement of 1995 CRA Regulations

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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

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

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

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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

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

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

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

Orrick, Herrington & Sutcliffe LLP

OCC releases April CRA performance evaluations

On May 1, the OCC released its CRA performance evaluations that became public during the month of April. The OCC evaluated 26 entities, including national banks, federal savings associations, and insured federal branches of...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

McGuireWoods LLP

Banks May Provide Cryptocurrency Transaction and Custody Services, but OCC Has Yet to Provide Clear Compliance Requirements

McGuireWoods LLP on

On May 7, 2025, the Office of the Comptroller of the Currency (“OCC”) issued a follow up to its July 2020 Interpretative Letter 1170, which allowed national banks to provide cryptocurrency custody services to their customers....more

Orrick, Herrington & Sutcliffe LLP

Regulators withdraw crypto guidance, plan further clarity for banks

On April 24, the FDIC and the Fed announced they have retracted two joint statements concerning banking organizations’ activities related to crypto-assets. According to the agencies, this move aims to clarify that banking...more

Orrick, Herrington & Sutcliffe LLP

OCC releases April 2025 enforcement actions

On April 17, the OCC announced enforcement actions against three institution-affiliated parties, alleging in the first instance fund misappropriation, in the second Paycheck Protection Program fraud, and in the last...more

Ballard Spahr LLP

OCC, FDIC eliminating ‘reputational risk’ from supervision, examinations

Ballard Spahr LLP on

The OCC has removed “reputational risk” from its handbooks and guidance and the FDIC is moving to do the same. ...more

Alston & Bird

Federal Banking Agencies Announce Intent to Rescind 2023 Community Reinvestment Act Final Rule and Return to Prior Framework

Alston & Bird on

What Happened? The Federal Deposit Insurance Corporation (“FDIC”), Board of Governors of the Federal Reserve System (“Federal Reserve”) and the Office of the Comptroller of the Currency (“OCC”), (collectively, “federal...more

King & Spalding

OCC Clarifies Crypto-Asset Guidance

King & Spalding on

The Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) have both recently taken actions and issued statements that indicate a more permissive bank regulatory approach to...more

Mayer Brown

OCC Withdraws Climate Risk Management Principles

Mayer Brown on

On March 31, 2025, the Office of the Comptroller of the Currency withdrew its participation in the interagency principles for climate-related financial risk management for large financial institutions (the “Climate...more

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