The Federal Reserve Board, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency have issued a joint statement on crypto-asset risks to banking organizations.  The term “crypto-asset” refers to any digital asset implemented using cryptographic techniques.

The statement begins with the agencies’ observations that “[t]he events of the past year have been marked by significant volatility and the exposure of vulnerabilities in the crypto-asset sector” and that “[t]hese events highlight a number of key risks associated with crypto-assets and crypto-asset sector participants that banking organizations should be aware of.”… Continue Reading

In recent remarks at the CRA & Fair Lending Colloquium, Grovetta Gardineer, Senior Deputy Comptroller for Bank Supervision Policy at the Office of the Comptroller of the Currency, discussed the OCC’s current fair lending initiatives.  Her remarks were intended to convey the message that the OCC is “laser focused on fair lending” and considers fair lending compliance to be an important component of safety and soundness.… Continue Reading

The OCC’s announcement that it will establish an Office of Financial Technology to “bolster the agency’s expertise and ability to adapt to a rapidly changing banking landscape” should come as no surprise to those who have been following recent pronouncements of Acting Comptroller Michael J. Hsu.

Over the past few months, Mr.… Continue Reading

In remarks at the DC Fintech Week conference on October 11, 2022 and in a keynote address later the same day at a roundtable conducted by the Harvard Law School  Program on International Financial Systems, Acting Comptroller of the Currency Michael J. Hsu expressed concerns about risks to consumers and the financial system posed by crypto industry participants.… Continue Reading

Since the beginning of Michael Hsu’s tenure as Acting Comptroller of the Currency, bank/fintech partnerships have been a focus of OCC concern.  Although bank lending partnerships with fintechs continue to receive OCC attention, recent remarks by OCC officials indicate that OCC scrutiny is now also directed at partnerships outside of the lending arena.… Continue Reading

On August 10, 2022, four Senators, Elizabeth Warren (D-MA), Dick Durbin (D-IL), Sheldon Whitehouse (D-RI), and Bernie Sanders (I-VT), sent a letter to Acting Comptroller of the Currency Michael Hsu, asking him to reverse four interpretive letters regarding whether it is permissible for national banks to provide cryptocurrency services.

Under Mr.… Continue Reading

In response to a request from three Democratic House members, the GAO recently issued a report on its review of fair lending oversight conducted by the Office of the Comptroller of the Currency.  According to a Law360 report, the lawmakers had petitioned the GAO nearly two years ago to open an investigation into allegations that the OCC had quietly dropped several fair lending investigations during the Trump Administration. … Continue Reading

On June 23, 2022, the Office of the Comptroller of the Currency (OCC) released its Semiannual Risk Perspective (SRP) for spring 2022.  In the SRP, the OCC opines on its current safety and soundness concerns for banks under its regulatory umbrella, focusing on Russia sanctions, climate-related risk, and rising inflation.  Despite these challenges, the OCC believes that “[b]anks’ financial condition remains strong and positioned to deal with the economic headwinds.”… Continue Reading

As we previously reported, the Office of the Comptroller of the Currency (“OCC”) rescinded its 2020 Community Reinvestment Act (“CRA”) final rule (the “2020 CRA Final Rule” or the “Rescinded Rule”) in December 2021 and has since been operating under a CRA framework largely based on the OCC’s 1995 CRA rule (the “1995 Rule”), which was adopted jointly with the Federal Reserve and the FDIC. … Continue Reading