On June 24, 2024, the Office of the Comptroller of the Currency (the “OCC”) issued a notice of proposed rulemaking (the “Proposal”) that would amend its recovery planning guidelines for…
On June 20, 2024, the Federal Deposit Insurance Corporation (“FDIC”) issued a final rule comprehensively restating and expanding its resolution planning rule (the “IDI Rule”) applicable to large insured depository…
In a speech on May 27, 2024, Acting Comptroller of the Currency, Michael J. Hsu, stated that expanding the application of the Office of the Comptroller of the Currency’s (“OCC”)…
Introduction On April 10, 2024, the Federal Deposit Insurance Corporation (the “FDIC”) released a report regarding Title II of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank…
I. Introduction In the wake of the industry’s 2022 “crypto winter,” which spiraled into a “cryptopocalyse,” industry watchers were focused on the contagion effect of the various crypto-related bankruptcy filings. …
On Monday, January 23, 2022, the New York Department of Financial Services (the “DFS”) released a letter (the “Guidance”) clarifying virtual currency custody and disclosure standards and practices that the…
On December 19, 2022, FTX Trading Ltd. issued a press release announcing a process for the voluntary return of avoidable pre-bankruptcy payments to “secure the prompt return of such funds…
As we approach the end of the year, here are the Top 10 posts on the Debevoise Fintech Blog in 2022. If you are not already a Blog subscriber, click…
On December 8, 2022, the Securities and Exchange Commission’s (“SEC”) Division of Corporation Finance (the “Division”) released a sample comment letter (the “Letter”) regarding recent developments in crypto asset markets. …
In the wake of the industry’s recent significant bankruptcy filings, crypto watchers are focusing for the first time on which crypto-entities are eligible for chapter 11 relief[1] under the U.S.…