Insights

Office of the Comptroller of the Currency

Federal Reserve Hardens Stance Towards Crypto, Denies Bank Membership

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What’s Happening Federal Reserve (FRB) denies membership and master account application for state-chartered Custodia Bank with crypto-focused business model FRB presumptively prohibits banks it supervises from holding crypto as principal…
Office of the Comptroller of the Currency

Regulators Warn on Interest Rate Risks, Banks Should Prepare for Scrutiny

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Rising interest rates are adversely affecting bank investment portfolios, leaving banks with a difficult set of choices. Regulators increasingly are expressing concern with the effect of interest rate risk. Banks must ensure their…
Office of the Comptroller of the Currency

Fifth Circuit Issues Decision on CFPB Funding, Vacates 2017 Payday Lending Rule

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Ruling finds CFPB funding unconstitutional, seeks to distinguish CFPB funding from other self-funded agencies. Fifth Circuit vacates 2017 Payday Lending Rule on grounds that it was promulgated using funds obtained outside of the Congressional…
Office of the Comptroller of the Currency

Our Op-Ed in the American Banker: An Unworkable Compromise on Stablecoins

The crypto industry yearns for legislative clarity on stablecoins, but the industry and consumers may be better off under the status quo than a flawed compromise. A one-size-fits-all approach could squash innovation. Expanding Federal…
Office of the Comptroller of the Currency

Federal Reserve Board Provides Additional Information for Banks Interested in Crypto-Related Activities

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Federal Reserve outlines step-by-step process for banks considering crypto-related activities. Despite efforts to add controls to crypto activities, several senators still believe crypto-related activities pose too great a risk for national…
Office of the Comptroller of the Currency

Federal Reserve Board Announces Updated Guidelines for Account Access, But Questions Remain

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Federal Reserve Board introduces three-tiered review system for access to its payments system. Federally insured banks will on average have less stringent reviews, while nonbanks will receive the most diligence and scrutiny. Despite…
Office of the Comptroller of the Currency

Senators Pressure OCC to Rescind Crypto Bank Guidance, Adding Regulatory Uncertainty

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Senators ask the Office of the Comptroller of the Currency (OCC) to rescind interpretive letters clarifying banks’ authority to engage in crypto-related activities. Despite efforts adding controls to crypto activities, senators still…
Office of the Comptroller of the Currency

Banking Regulators Propose CRE Loan Policy Update, Signal Concerns for Upcoming Business Cycle

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Updated statement signals concern from agencies about the impact of slowing economy on CRE lenders and borrowers. Proposed statement affirms that lenders will not be criticized for implementing certain CRE loan workouts and accommodations. …
Office of the Comptroller of the Currency

Randall Kroszner Featured in Yahoo Finance Article on the Economy

Randall Kroszner, former Federal Reserve Board (FRB) Governor and Senior Advisor at Patomak Global Partners, was featured in Yahoo Finance yesterday. Mr. Kroszner commented on the likelihood of a recession in the United States, stating that…
Office of the Comptroller of the Currency

Question and Answer with Keith Noreika: Perspectives on Issues Facing Banks Now

In the following interview, Keith Noreika shares his thoughts on issues facing banks today as well as current events and regulatory developments shaping the near-term horizon. Mr. Noreika joined Patomak Global Partners in July 2022 as Executive…