A new program addresses innovative banking activities such as bank-fintech partnerships and digital assets while reinforcing guardrails around stablecoin activity. By Arthur S. Long, Parag Patel, Pia Naib, Ja Hyeon Park, and Deric Behar On August 8, 2023, the Board of Governors of the Federal Reserve System (FRB) issued guidance to the banking organizations that … Continue Reading
The guidance outlines principles and key considerations for banking organizations as they navigate risks associated with third parties, including fintechs. By Arthur S. Long, Parag Patel, Barrie VanBrackle, Pia Naib, Ja Hyeon Park, Victor Razon, and Deric Behar On June 6, 2023, the Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal Reserve … Continue Reading
Custodia Bank was denied Federal Reserve membership, while certain crypto principal activities are deemed presumptively not appropriate for member banks. By Arthur S. Long, Pia Naib, and Deric Behar On January 27, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve) took two actions, clarifying that it considers many cryptocurrency activities to be … Continue Reading
Banking organizations should ensure appropriate risk management, but regulators are skeptical of certain crypto activities as principal. By Arthur S. Long, Pia Naib, and Deric Behar On January 3, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency … Continue Reading
The Federal Reserve is taking measured steps to better understand the types of cryptoasset-related activities contemplated by its supervised banking organizations. By Alan W. Avery, Pia Naib, and Deric Behar On August 16, 2022, the Board of Governors of the Federal Reserve System (FRB) issued a Supervision and Regulation Letter outlining its expectations for FRB-supervised … Continue Reading
Regulators once again offered piecemeal guidance, while focusing on risks and enforcement. Meanwhile, innovation and institutional adoption took off. By Stephen P. Wink, Todd Beauchamp, Yvette D. Valdez, Eric S. Volkman, Adam Bruce Fovent, and Deric Behar Last year, Latham & Watkins sounded a hopeful note that 2020 would provide a clearer vision than 2019 … Continue Reading
The OCC greenlights bank custody of cryptoassets, opening a significant door to mainstream adoption and innovation. By Alan W. Avery, Todd Beauchamp, Yvette D. Valdez, Pia Naib, Loyal T. Horsley, Charles Weinstein, and Deric Behar On July 22, 2020, the US Office of the Comptroller of the Currency (OCC) issued Interpretive Letter #1170 (the Letter), … Continue Reading
Federal court allows NYSDFS lawsuit against OCC FinTech charter to proceed, raising further questions about the charter’s viability. By Alan W. Avery, Todd Beauchamp, Loyal T. Horsley, Pia Naib, and Charles Weinstein In a May 2 order, US District Court Judge Victor Marrero rejected the Office of the Comptroller of the Currency’s (OCC’s) recent motion … Continue Reading
