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The Federal Reserve’s Shift in Supervision Strategy for Novel Activities

By James Stevens & Sarah Hanna on August 19, 2025
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On August 15, the Federal Reserve Board announced a significant shift in its approach to supervising novel activities within banking organizations. The Board decided to sunset its Novel Activities Supervision Program, which was initially established to enhance oversight of activities related to crypto-assets, distributed ledger technology (DLT), and complex partnerships with non-banks. This program, launched in 2023, aimed to address the unique risks posed by these innovative financial activities, ensuring they were appropriately managed within the banking sector.

The decision to integrate the supervision of these activities back into the standard supervisory process reflects the Board’s strengthened understanding of the associated risks and bank risk management practices. Over the past two years, the Novel Activities Supervision Program has provided valuable insights into the complexities and challenges posed by financial innovations. By rescinding the supervisory letter that created the program, the Board signals its confidence in the existing supervisory framework’s ability to manage these activities effectively.

This move aligns with the Federal Reserve’s broader strategy to balance innovation with financial stability. While the program was instrumental in enhancing technical expertise and developing supervisory approaches, the Board now believes that the standard supervisory process can adequately address the risks without the need for a separate program.

Photo of James Stevens James Stevens

James is the co-leader of the firm’s Financial Services Industry Group. He has significant experience working with clients across the entire financial services sector, regularly working with public and private companies such as banks, neobanks, marketplace lenders, and other fintech and financial services…

James is the co-leader of the firm’s Financial Services Industry Group. He has significant experience working with clients across the entire financial services sector, regularly working with public and private companies such as banks, neobanks, marketplace lenders, and other fintech and financial services providers and partners.

Read more about James StevensEmail
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Photo of Sarah Hanna Sarah Hanna

Sarah is an associate in the firm’s Corporate practice. She works with public and private companies on a wide range of corporate matters, including equity and debt offerings, SEC reporting, corporate governance, and financial services matters.

Read more about Sarah HannaEmail
  • Posted in:
    Banking, Finance and Securities
  • Blog:
    Financial Services Blog
  • Organization:
    Troutman Pepper Locke
  • Article: View Original Source

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