On January 20, President Biden’s Chief of Staff Ronald Klain issued a memorandum to the heads of executive departments and agencies setting forth the terms of a regulatory freeze.

The memorandum requires the following subject to limited exceptions:

  • No rules can be issued or proposed until a department or agency head appointed by President Biden

On January 5, 2021, the Attorneys General of New York, California, Colorado, the District of Columbia, Massachusetts, Minnesota, New Jersey, and North Carolina filed a voluminous Complaint in federal district court for the Southern District of New York against the OCC and Acting Comptroller of the Currency Brian Brooks, seeking to set aside the final

On January 4, 2021, the Office of the Comptroller of the Currency (“OCC”) published an Interpretive Letter clarifying the authority of national banks and federal savings associations to participate in independent node verification networks (“INVN”) and use stablecoins to conduct payment activities and other bank-permissible functions.

A stablecoin is a type of cryptocurrency that is

After reviewing the proposal’s statutory basis, coverage, and operative requirements, Mr. Court explains the basis for BPI’s position that the proposal is inconsistent with how banking is regularly conducted and will undermine rather than promote safety and soundness, provides examples of how the proposal would impose unworkable requirements, and discusses BPI’s Freedom of Information Act

The Conference of State Bank Supervisors (CSBS) has filed a lawsuit in D.C. federal district court to block the OCC from granting a national bank charter to Figure Technologies Inc.  According to the complaint, Figure, through a subsidiary, is currently licensed in 49 states and the District of Columbia as a mortgage lender, consumer lender,

The Chief Counsel of the Office of the Comptroller of the Currency has issued Interpretive Letter 1173, addressing national bank and federal savings association preemption of state law under the Dodd-Frank Act.

The Interpretive Letter clarifies that the special Dodd-Frank preemption requirements for “preemption determinations” are limited as follows:

  • “Preemption determinations” are confined to

On December 18, 2020, the Office of the Comptroller of the Current (OCC), Federal Reserve Board (FRB), and Federal Deposit Insurance Corporation (FDIC) announced an interagency notice of proposed rulemaking that would require supervised banking organizations to provide notification of significant computer security incidents to their primary federal regulator.  Under the proposed rule, for incidents

The Attorneys General of California, Illinois, and New York have filed a motion for summary judgment in their lawsuit filed against the Office of the Comptroller of the Currency (OCC) to enjoin the OCC’s final rule purporting to override the Second Circuit’s Madden decision as to national banks and federal savings associations.  The OCC must

Earlier this month, House Financial Services Committee Chairwoman Maxine Waters sent a letter to President-elect Joe Biden recommending various actions that the Biden Administration should take in the financial services arena.  Chairman Waters and members of her staff are expected to have a strong voice in shaping the Biden Administration’s approach to financial services regulatory