- The OCC issued an interim final rule clarifying that national banks have longstanding authority to charge non-interest fees (including interchange fees) regardless of whether those fees are
OCC Preempts Illinois Interchange Fee Law
FCA Consultation on Cryptoasset Perimeter Guidance: Key Points for DeFi and Web3 User Interfaces and Wallets
The guidance defines certain regulated cryptoasset activities broadly, potentially placing onerous authorisation obligations on DeFi and web3 user interfaces and wallets.
By Stuart Davis, Gabriel Lakeman, Brett Carr, Cameron Jones, and Imaan Nazir
On 15 April 2026, the FCA published draft perimeter guidance (in CP 26/13) that, if finalised in its current form, could bring a large segment of global web3 interface providers and wallets within scope of UK cryptoasset licensing requirements. The guidance interprets
SEC Staff Issues Statement on Broker-Dealer Registration for Cryptoasset Securities Interfaces
- The Statement lists 12 conditions (including routing transparency, disclosures, and the absence of discretionary functions) under which the Staff will not object to a Covered User Interface Provider operating without broker-dealer registration.
- The Staff permits Covered
SEC Clarifies the Application of the Securities Laws to Cryptoassets
- Establishes a five-part token taxonomy of cryptoassets comprising digital commodities, digital collectibles, digital tools, stablecoins,
FCA Outlines Priorities in Annual Report on Payments Sector
- Identifying and quickly closing gaps in their compliance with
What the CFTC’s New No-Action Relief Really Means for Self-Custody Crypto Wallets
- The relief is a meaningful and incremental expansion on existing CFTC staff no-action relief on passive technology service provider and independent software vendor activities.
- While the no-action relief is specific to Phantom and is not issued as wide-spread market relief, it provides insight
SEC and CFTC Sign Landmark Memorandum of Understanding on Regulatory Harmonization
- The agencies plan to clarify product definitions and oversight through joint interpretations and rulemakings, including a fit-for-purpose regulatory framework for cryptoassets and other emerging technologies.
- The agencies
OCC Issues Proposal to Implement the GENIUS Act
The Proposal would establish many requirements for OCC supervised entities, including reserves, capital standards, redemption timelines, and the extent of OCC supervisory authority.
By Jenny Cieplak, Arthur S. Long, Parag Patel, Yvette D. Valdez, Barrie VanBrackle, Pia Naib, and Deric Behar
On February 25, 2026, the Office of the Comptroller of the Currency (OCC) issued a Notice of Proposed Rulemaking (the Proposal) to implement the Guiding and Establishing National Innovation for US Stablecoins Act
OCC Finalizes Rule on National Trust Bank Activities
The Rule provides critical regulatory clarity for entities seeking national trust bank charters to engage in digital asset activities.
By Arthur S. Long, Parag Patel, Pia Naib, and Deric Behar
Key Points
- The Final Rule amends the OCC’s chartering regulations to clarify that national trust banks are not limited to fiduciary activities as defined in the OCC’s regulations.
- The Final Rule is framed as a clarification to reduce regulatory ambiguity, not a change in chartering authority.
Introduction
Federal Court Partially Upholds Illinois Law Limiting Interchange Fees
The decision clears a legal path for state-level regulation of credit and debit card swipe fees (while striking down data usage restrictions), setting the stage for a high-stakes appeal.
By Arthur S. Long, Jack McNeily, Parag Patel, Barrie VanBrackle, Pia Naib, and Deric Behar
Updated on March 5, 2026
On March 2, 2026, the Seventh Circuit granted the banking and credit union trade groups’ unopposed motion to fast-track their appeal, seeking resolution on whether and