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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…

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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

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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…

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  • The FDIC plans to propose an application process for stablecoin issuance by FDIC-regulated institutions by the end of 2025, and is also collaborating with other banking regulators to develop broader prudential standards for all stablecoin issuers as required under the GENIUS
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Regulators are directed to avoid reputation risk, identify banks that have engaged in unlawful debanking, and take appropriate remedial actions.

By Marc P. Berger, Betty M. Huber, Arthur S. Long, Benjamin Naftalis, Parag Patel, Stephen P. Wink, Douglas K. Yatter, Pia Naib, and Deric Behar

On August 7, 2025, President Trump issued an executive order titled “Guaranteeing Fair Banking for All Americans” (the Order). The Order, described further in an accompanying fact…

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The statute’s new regulatory framework for payment stablecoins paves the way for increased digital asset adoption and innovation.

On July 18, 2025, President Trump signed into law the Guiding and Establishing National Innovation for US Stablecoins Act (the GENIUS Act), legislation that establishes a regulatory framework for payment stablecoins. It is the first federal legislation on digital assets to be enacted since President Trump issued an executive order aiming to make the US the “crypto capital of the world.”

First…

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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.

By Arthur S. Long, Parag Patel, Pia Naib, and Deric Behar

On July 14, 2025, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the agencies) issued a joint statement (the Joint Statement) on risk-management…

The federal banking agencies continue to open the channels for regulated entities to engage in digital asset activities.

By Arthur S. Long, Parag Patel, Pia Naib, and Deric Behar

On May 7, 2025, the Office of the Comptroller of the Currency (OCC) published Interpretive Letter 1184 (a response to an inquiry from a regulated entity) affirming that national banks and federal savings associations (collectively, banks) may provide and outsource cryptocurrency custody and execution services on behalf of…