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Regulatory Requirements Office of the Comptroller of the Currency Risk Management

Morrison & Foerster LLP

Crypto-Asset Safekeeping: What’s Involved If You’re a Bank (or if You Want to Be One)

On July 14, 2025, the federal banking agencies issued a joint statement to clarify regulatory expectations for banking organizations that provide or are considering providing safekeeping for crypto-assets (“Joint Statement”)....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

Latham & Watkins LLP

Banking Agencies Issue Joint Statement on Risk-Management Considerations for Cryptoasset Safekeeping

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Banking organizations safekeeping digital assets for customers must do so in a safe and sound manner and in compliance with applicable laws and regulations....more

Sheppard Mullin Richter & Hampton LLP

Federal Banking Regulators Issue Joint Guidance on Crypto-Asset Safekeeping

On July 14, the OCC, Federal Reserve, and FDIC announced the release of a joint statement clarifying how existing laws and regulations apply to crypto-asset safekeeping services offered by banking organizations. The statement...more

Orrick, Herrington & Sutcliffe LLP

Prudential regulators release statement on cryptocurrency safekeeping

On July 14, the OCC, the Fed, and the FDIC issued a joint statement addressing how existing laws, regulations and governing principles apply to banks which provide or are considering providing safekeeping for...more

Troutman Pepper Locke

Federal Agencies Release Guidance on Crypto-Asset Safekeeping for Banks

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On July 14, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (the Board), and the Federal Deposit Insurance Corporation (FDIC) jointly issued a statement addressing the...more

Jones Day

Banking on Crypto: Regulators Clarify Rules for Digital Asset Safekeeping

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Federal banking regulators continue to promote a more "crypto-positive" regulatory environment through recent joint guidance issued to clarify risk management and compliance expectations for banks providing crypto-asset...more

Troutman Pepper Locke

OCC Patriot Bank Order Spotlights AML Issues For Managers

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On Jan. 14, Patriot Bank, based in Stamford, Connecticut, entered into an agreement with the Office of the Comptroller of the Currency to address and rectify several alleged unsafe or unsound practices and violations of law....more

Loeb & Loeb LLP

Banking Agencies Propose Long-Sought Changes to Capital Rules for the Largest U.S. Banks

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The Federal Reserve, alongside the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC), released their highly anticipated Notice of Proposed Rulemaking to overhaul the Enhanced...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

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

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

Troutman Pepper Locke

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

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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

OCC releases semiannual Interest Rate Risk Statistics Report

Recently, the OCC released its Spring 2025 Interest Rate Risk Statistics Report detailing interest rate risk data gathered during examinations of OCC-supervised midsize and community banks and federal savings associations....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 clarifies crypto-asset activities in interpretive letter

On May 7, the OCC clarified permissible activities for national banks and federal savings associations regarding crypto-asset custody and execution services by publishing Interpretive Letter 1184. This letter confirmed...more

Latham & Watkins LLP

OCC Affirms Banks Can Engage in Crypto Custody and Execution Activities

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The federal banking agencies continue to open the channels for regulated entities to engage in digital asset activities. On May 7, 2025, the Office of the Comptroller of the Currency (OCC) published Interpretive Letter...more

McGuireWoods LLP

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

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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

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

Ballard Spahr LLP

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

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

Orrick, Herrington & Sutcliffe LLP

OCC provides an update on its security breach given institutional risk

On April 14, the OCC released a letter providing more details on the recent security breach involving its email systems. The breach — identified as a major incident under the Federal Information Security Modernization Act...more

Jones Day

OCC Ends Climate Risk Guidance for Large Banks

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In a recent shift, the Office of the Comptroller of the Currency (OCC) has officially ended its climate risk guidance for large U.S. banks. The 2021 guidance called on major banks to incorporate climate-related risks into...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

Orrick, Herrington & Sutcliffe LLP

OCC releases March 2025 enforcement actions

On March 20, the OCC released a list of recent enforcement actions taken against national banks, federal savings associations, and individuals affiliated with supervised banks. Among the actions taken, the OCC issued a cease...more

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