The inter-agency crypto-asset policy sprint initiative has finally taken off. This morning the Federal Reserve Board, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency (collectively, “the Agencies”) issued their first joint statement (the “Statement”) summarizing progress on a series of crypto-asset[1] policy sprints and revealing next steps. The Statement is a continuation of an…
On November 21, 2021, the Office of the Comptroller of the Currency (“OCC”) published a letter “clarifying” that certain cryptocurrency, distributed ledger and stablecoin activities addressed in three prior interpretive letters may be conducted only after a national bank or federal savings association receives a non-objection from its supervisory office (the “Letter”). The Letter also clarifies that a prior interpretive…
On November 9, 2021, the Basel Committee on Banking Supervision (the “BCBS”) issued a press release that, among other things, reiterated its commitment to developing a “conservative risk-based global minimum standard” to address potential risks to the banking system arising from crypto-assets. This announcement followed a June 10, 2021 public consultation, a December 12, 2019 discussion paper and a March…
On November 1, 2021, the President’s Working Group on Financial Markets,[1] the Federal Deposit Insurance Corporation (the “FDIC”) and the Office of the Comptroller of the Currency (collectively, the “Financial Regulators”) jointly published a report (the “Report”) outlining the financial risks associated with the use of stablecoins as a means of payment and the need to address current gaps in…
On July 9, 2021, President Biden issued a sweeping Executive Order (the “Order”)[1] on competition. While the Order is directed to agencies across the federal government and will have wide-ranging implications for various business sectors, this post focuses specifically on the provisions of relevance to evaluating the potential impact on bank mergers and acquisitions. The Order “encourages” the Department of…