OCC Bulletins 2025-22 and 2025-23 clarify the agency’s approach to evaluating banks’ compliance with fair banking practices and protecting customers’ financial records.
By Betty M. Huber, Arthur S. Long, Parag Patel, Pia Naib, Ed Reynolds, Richard Reynolds, and Deric Behar
The Office of the Comptroller of the Currency (OCC)1 published two bulletins (Bulletins 2025-22 and 2025-23) in September 2025 aimed at eliminating unlawful debanking in the federal banking system. Bulletins 2025-22 and
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
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
In a break from restrictive Biden-era policies, OCC-supervised banks may now engage in crypto without supervisory nonobjection, potentially opening new avenues for innovation.
By Arthur S. Long, Parag Patel, Pia Naib, and Deric Behar
On March 7, 2025, the Office of the Comptroller of the Currency (OCC) reaffirmed that national banks and federal savings associations (collectively, banks) may participate in a range of cryptocurrency activities, including crypto custody, certain stablecoin activities, and participation in independent node verification
Under its new acting chairman appointed by President Trump, the FDIC charges ahead with its new agenda by rolling back key Biden-era regulatory efforts.
By Arthur S. Long, Pia Naib, and Deric Behar
On March 3, 2025, the Federal Deposit Insurance Corporation (FDIC) announced that its Board of Directors1 voted to rescind the agency’s 2024 Statement of Policy on Bank Merger Transactions and withdraw four other Biden-era proposals.
The sweeping purge effectuates Acting Chairman Travis Hill’s top
The FDIC seeks to stick to its statutory mandate while reducing impediments to fintech, innovation, mergers, bank formation, and efficient supervision.
By Arthur S. Long, Pia Naib, and Deric Behar
Just one day after being named acting chairman of the Federal Deposit Insurance Corporation (FDIC), Travis Hill revealed an agenda of priorities for the FDIC. Hill previewed many of the priorities during his January 10, 2025, remarks on FDIC policy issues at the American Bar Association (ABA), where