Overview
On Friday, March 7, 2025, the new leadership of the Office of the Comptroller of the Currency (the “OCC”) took initial steps in what we believe to be a broader effort to liberalize the OCC’s approach to regulating crypto-asset
Debevoise & Pimpton FinTech Blog
The Debevoise & Plimpton FinTech Blog focuses on legal and regulatory developments affecting the financial technology sector, including crypto-assets, blockchain, and digital payments. It covers regulatory changes and guidance from U.S. financial authorities such as the OCC, FDIC, and Federal Reserve, particularly regarding crypto-asset activities by banks and financial institutions. The blog also addresses broader financial regulatory topics like recovery planning for large banks, data privacy and security regulations related to sensitive personal data, and the impact of U.S. political developments on financial services regulation. It is published by Debevoise & Plimpton and reflects the firm's expertise in banking, capital markets, national security, and white collar legal issues.
Latest from Debevoise & Pimpton FinTech Blog - Page 2
Crypto Assets under the Trump Administration
By Cnswett
Debevoise & Plimpton LLP has published a guide on the Trump administration’s approach to the crypto-asset industry, including potential regulatory implications and outlook. The key takeaways from the guide, which was authored by lawyers from the firm’s Banking, Capital Markets,…
Biden Administration Proposes to Limit Access to Sensitive Personal Data by Countries of Concern
The Department of Justice (“DOJ”) has moved ahead with its effort to protect Americans’ sensitive personal data and U.S. government data from exploitation by countries of concern or related covered persons, issuing a Notice of Proposed Rulemaking (the “Proposal”) that…
U.S. Election 2024: Financial Services Outlook
By Cnswett
Debevoise & Plimpton LLP has published a guide to the potential impact of the U.S. election on the financial services industry, including possible regulatory implications. The key takeaways from the guide, which was authored by 18 lawyers from the firm’s
…
OCC Proposes Expanding Recovery Plan Guidelines to Banks with $100 Billion or More
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 large insured banks under OCC oversight (i.e., national banks, federal…
FDIC Finalizes Rules Revamping IDI Resolution Plan Requirements
By Abarone
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 institutions (“IDIs”).[1] The release finalizes the rule proposal from…
Acting Comptroller Hsu Hints at Expanding OCC Recovery Plan Guidelines to Banks with $100 Billion or More
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”) recovery guidelines (the “Recovery Guidelines”) to all large banks under…
The FRB Proposes its Approach to More Rigorous Bank Merger Review
By Abarone
As detailed in our recent Debevoise in Depth articles,[1] both the Office for the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Cooperation (“FDIC”) have proposed changes to their Bank Merger Act (“BMA”) review policies, with the…
FDIC Report Expresses Confidence in GSIB Resolution, May Affect Large Regional Bank M&A Prospects and Strategy
By Abarone
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 Act“),[1] titled Overview of Resolution Under Title II of…
The FDIC Proposed Supplement to the Bank Merger Act Application Form
By Jamoore
Hundreds of hours’ worth of changes and additions proposed for applicants
On March 21, 2024, the Federal Deposit Insurance Corporation (“FDIC”) published a proposed update to its Statement of Policy on Bank Merger Transactions, detailed in our March 27, 2024…