Cleary Gottlieb Discusses OCC’s Proposed Updates to Digital Banking, Bank Activity Rules

On June 4, the Office of the Comptroller of the Currency published a Proposal to update rules applicable to the activities and operations of national banks and Federal savings associations.  Comments on the Proposal are due August 3.  Simultaneously with the Proposal, the OCC released an Advance Notice of Proposed Rulemaking requesting comment on expanding, updating and improving the regulations and interpretations on digital and electronic activities.  The ANPR is quite open-ended, and we anticipate that comments are likely to take many forms, from direct responses to white papers and research analyses.  Comments on the ANPR are also requested … Read more

Cleary Gottlieb Discusses New Law Revising Dodd-Frank Act

The Economic Growth, Regulatory Relief, and Consumer Protection Act (the “Act”), which became law on May 24, contains the first major package of revisions to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.  The Act leaves the architecture and core features of Dodd-Frank intact but significantly recalibrates applicability thresholds.  While the changes mandated by the Act are significant, it also places significant discretion for further changes in the hands of the Federal Reserve Board.

Both the House of Representatives and the Senate passed the Act on bipartisan votes.  The Chairman of the House Financial Services … Read more