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Regulatory Reform Banks Office of the Comptroller of the Currency

Ballard Spahr LLP

Trump issues Executive Order prohibiting ‘debanking’

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President Trump has issued an Executive Order directing banking agencies to adopt policies to ensure that financial institutions do not use reputational risk as a basis for restricting access to banking services—a process...more

Jones Day

With New Action Plan, White House Launches AI "Space Race"—What Banks Should Know

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The White House has issued an AI Action Plan that aims to position the United States as the leader in artificial intelligence ("AI"), as part of a broader pattern of boosting innovation and reducing regulatory burden, with...more

Cadwalader, Wickersham & Taft LLP

Global Moves, Digital Shifts, July 2025 - Fed, FDIC and OCC Issue Proposed Rulemaking to Rescind 2023 CRA Rule

Last week, the Federal Deposit Insurance Corporation (“FDIC), Federal Reserve Board (“FRB”), and the Office of the Comptroller of the Currency (“OCC”) (collectively, “the Agencies”)  issued a proposed rulemaking to both...more

Orrick, Herrington & Sutcliffe LLP

OCC removes reference to disparate impact for examiners

On July 14, the OCC announced it has removed the references to disparate impact liability from the “Fair Lending” booklet of the Comptroller’s Handbook and has started removing references in other issuances. The OCC has also...more

Latham & Watkins LLP

Banking Regulators Propose to Ease Enhanced Supplementary Leverage Ratio for Large US Banks

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The proposal aims to free up large bank balance sheets and promote US Treasury market intermediation, which the current regulations may hinder....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

Orrick, Herrington & Sutcliffe LLP

Agencies allow banks to access tax ID numbers from third parties

On June 27, the OCC, FDIC and NCUA, with the concurrence of FinCEN, granted an exemption allowing banks to use a third party source to obtain customer tax identification numbers (TIN) for customers before opening an account....more

Ballard Spahr LLP

Financial institutions may rely on third parties for Social Security, Taxpayer Identification Numbers

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Banks and credit unions may now rely on third parties to provide a consumer’s Social Security or Taxpayer Identification Number, according to an order issued by the FDIC, OCC and the NCUA with the consent of the Financial...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

Fed announces that examination programs will no longer consider reputational risk

On June 23, the Fed announced it will no longer include reputational risk as a component of its examination programs in its supervision of banks. This move will align the Fed with the OCC, which made a similar announcement in...more

Perkins Coie

GENIUS Act Passes US Senate in Significant Step Towards Regulatory Clarity for Stablecoins

Perkins Coie on

The U.S. Senate passed the Guiding and Establishing National Innovation for U.S. Stablecoins Act or GENIUS Act (S.1582) (the Act) in a 68-30 bipartisan vote on June 17, 2025. The GENIUS Act would provide a clear regulatory...more

Sheppard Mullin Richter & Hampton LLP

Federal Reserve Board Removes Reputational Risk from Examination Ratings

On June 23, the Federal Reserve Board announced that reputational risk will no longer be a component of its bank-examination program. The same day, the Board released a revised edition of its Guidelines for Rating Risk...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

McGuireWoods LLP

OCC Reaffirms that its National Bank Preemption Regulations are Lawful

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On May 8, 2025, the Conference of State Bank Supervisors (“CSBS”) asked the Office of the Comptroller of the Currency (“OCC”) to comply with Executive Orders 14129 and 14267 by reversing its regulations governing national...more

Cadwalader, Wickersham & Taft LLP

Heating Up, June 2025 - OCC Defends Federal Bank Preemption

In response to a request from the Conference of State Bank Supervisors (“CSBS”), Acting Comptroller of the Currency, Rodney E. Hood, decisively defended OCC regulations regarding the ability of national banks and Federal...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

Nutter McClennen & Fish LLP

Nutter Bank Report: May 2025

The FDIC and OCC have rescinded policy statements adopted in 2024 that changed the ways each agency considered bank merger transactions and have reinstated their prior procedures for evaluating bank mergers. The FDIC on May...more

Husch Blackwell LLP

DE&I Rollbacks: Are Banks in the Crosshairs?

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In January 2025, the new Trump administration issued Executive Order 14173, which ordered all executive departments and agencies to, among other things, end federal “diversity, equity, and inclusion” (DEI) programs and to use...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

Orrick, Herrington & Sutcliffe LLP

Acting Comptroller discusses importance of financial inclusion

On May 8, Acting Comptroller of the Currency Rodney E. Hood spoke on his four priority areas: financial inclusion, reducing regulatory burdens, bank-fintech partnerships, and digital assets. He emphasized that financial...more

DLA Piper

Bank Regulatory News and Trends - May 2025

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This regular publication from DLA Piper focuses on helping banking and financial services clients navigate the ever-changing regulatory landscape....more

K&L Gates LLP

Federal Banking Regulators Adopt a Permissive Stance on Cryptocurrency

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The federal banking regulators have each recently adopted a more permissive approach to the regulation of cryptocurrency activities within the banking sector. The Office of the Comptroller of the Currency (OCC), the Federal...more

Lathrop GPM

White House Establishes a U.S. Strategic Bitcoin Reserve and Digital Asset Stockpile: What It Is and What It Implies

Lathrop GPM on

On March 6, President Trump issued an Executive Order establishing a Strategic Bitcoin Reserve capitalized by Government BTC and a U.S. Digital Asset Stockpile capitalized by other crypto assets. Creating the Strategic...more

Jones Day

Federal Reserve Withdraws Crypto-Related Guidance Including Notification Requirements for Banking Organizations

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The Federal Reserve Board ("Board") softened its stance on regulation of crypto activity by banking organizations by rescinding supervisory letters that created hurdles for crypto-asset activities and by joining the Office of...more

Orrick, Herrington & Sutcliffe LLP

Acting Comptroller outlines OCC’s strategic priorities

On April 16, Acting Comptroller of the Currency Rodney E. Hood delivered a speech and outlined his strategic focus areas since assuming the role two months ago. Hood emphasized the OCC’s mission to ensure a safe, sound and...more

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