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3 weeks ago | 
jdsupra.com | Alexandra Steinberg Barrage |Matthew Bornfreund |Ethan G. Ostroff
Last Friday, the Federal Deposit Insurance Corporation (FDIC) announced the rescission of Financial Institution Letter (FIL-16-2022) and issued new guidance clarifying the process for FDIC-supervised institutions to engage in crypto-related activities. The new Financial Institution Letter (FIL-7-2025) represents a 180 degree turn from the prior Chairman’s position, which required prior notification and relevant information by banks seeking to engage in crypto-related activities.
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1 month ago | 
jdsupra.com | Alexandra Steinberg Barrage |Matthew Bornfreund |Ethan G. Ostroff
On March 7, the Office of the Comptroller of the Currency (OCC) issued a significant update regarding the involvement of national banks and federal savings associations in cryptocurrency activities. Interpretive Letter 1183 reaffirms the permissibility of various crypto-asset activities and aims to streamline the regulatory process for banks engaging in these activities.
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1 month ago | 
lexology.com | Matthew Bornfreund |Ethan G. Ostroff |Alexandra Steinberg Barrage |James Stevens
On March 7, the Office of the Comptroller of the Currency (OCC) issued a significant update regarding the involvement of national banks and federal savings associations in cryptocurrency activities. Interpretive Letter 1183 reaffirms the permissibility of various crypto-asset activities and aims to streamline the regulatory process for banks engaging in these activities.
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1 month ago | 
lexology.com | Matthew Bornfreund |James Kim |Caleb Rosenberg |Alexandra Steinberg Barrage |Christopher J. Capurso |Taylor Gess
On January 8, Senate Bill No. 1252 (SB 1252) was introduced to the Virginia General Assembly, aiming to amend and reenact sections of the Code of Virginia related to the application of usury rates. Just two weeks ago, the bill was passed by both the House and Senate. Opponents of the bill contend that the language and effect is very unclear, but that broad language and stringent provisions could stifle innovation and ultimately harm consumers by limiting their access to credit.
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Jan 15, 2025 | 
jdsupra.com | Alexandra Steinberg Barrage |Matthew Bornfreund |James Kim
On January 10, the Consumer Financial Protection Bureau (Bureau) issued a notice of proposed interpretive rule (Proposed Rule). The deadline for comments is March 31, 2025. The Proposed Rule would apply the Electronic Fund Transfer Act (EFTA)—which protects consumers against errors and fraud—to new types of digital payment mechanisms, including stablecoins and other digital currencies.
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Jan 14, 2025 | 
jdsupra.com | Alexandra Steinberg Barrage |Matthew Bornfreund |Kevin Petrasic
On January 8, the United States District Court for the Southern District of New York dismissed the claims brought by Banco San Juan Internacional, Inc. (BSJI) against the Federal Reserve Bank of New York (FRBNY) and the Board of Governors of the Federal Reserve System (Board). BSJI alleged that the termination of its master account by the FRBNY violated various federal laws.
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Dec 10, 2024 | 
jdsupra.com | Matthew Bornfreund |Lori J. Sommerfield
On December 3, the Office of the Comptroller of the Currency (OCC) issued version 1.1 of the “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or Practices” booklet of the Comptroller’s Handbook, also known as the UDAAP booklet. The UDAAP booklet was last updated in June 2020. Key Updates in Version 1.1 Overdraft Services: The revised booklet offers enhanced guidance on sound risk management practices related to overdraft services.
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Dec 9, 2024 | 
openlegalblogarchive.org | Matthew Bornfreund |Lori J. Sommerfield
On December 3, the Office of the Comptroller of the Currency (OCC) issued version 1.1 of the “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or Practices” booklet of the Comptroller’s Handbook, also known as the UDAAP booklet. The UDAAP booklet was last updated in June 2020. Key Updates in Version 1.1Overdraft Services:The revised booklet offers enhanced guidance on sound risk management practices related to overdraft services.
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Dec 5, 2024 | 
jdsupra.com | Alexandra Steinberg Barrage |Matthew Bornfreund |James Kim
In the last two weeks, several amicus briefs were filed in the Tenth Circuit in the ongoing litigation concerning Colorado’s opt-out from the Depository Institutions Deregulation and Monetary Control Act (DIDMCA).
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Nov 20, 2024 | 
jdsupra.com | Alexandra Steinberg Barrage |Matthew Bornfreund |James Stevens
In a previous post, we discussed the Federal Deposit Insurance Corporation’s (FDIC) notice of proposed rulemaking aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank companies. The proposed rule initially set a public comment period ending on December 2, 2024. This week, the FDIC announced a 45-day extension to this comment period, now allowing stakeholders until January 16, 2025, to submit their feedback.
