Sky Blog
The Trump Administration’s May 19 executive order[1] on fintech innovation (the “Order”) seeks to force a sharp shift in the regulatory relationship between banks and other federally regulated financial services providers and what it calls “fintech”—any financial service offered …
To encourage the participation of private investors such as private equity firms in the acquisition of failed banks, the FDIC on March 19 approved the rescission of its 2009 Statement of Policy on the Qualifications for Failed Bank Acquisitions.[1]…
Banking organizations must ensure that a tokenized security confers identical legal rights as its non-tokenized counterpart to qualify for the same capital treatment as the non-tokenized form of the security, according to new guidance from the federal banking agencies.
On February 25, 2026, the Office of the Comptroller of the Currency (the “OCC”) issued a proposal to implement significant portions of the Guiding and Establishing National Innovation for U.S. Stablecoins Act, known as the GENIUS Act (the “Act”), which …
The Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation (collectively, the federal banking agencies) issued new frequently asked questions on how tokenized securities are treated under the capital rules.1
The environment has never been more favorable for existing banking organizations launching a digital asset business and those Fintech and other nonbank companies considering acquiring or chartering a full-service or limited-purpose bank in order to operate a digital asset business. …
The Federal Reserve and FDIC took actions last week designed to facilitate crypto-related activities. The Federal Reserve rescinded its anti-crypto 2023 policy statement and replaced it with a more permissive stance designed to facilitate innovation, and requested information on a …
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On October 7, 2025, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency (the “agencies”) jointly issued a notice of proposed rulemaking (“NPR”)[1] that would codify the removal of reputation risk from the agencies’ …
On September 8, 2025, the Fifth Circuit issued its opinion in Ortega v. Office of the Comptroller of the Currency, 2025 WL 2588495 (5th Cir. Sept. 8, 2025). Petitioners, former directors of a national bank, challenged the OCC’s …
On July 30, 2025, the White House released a report titled “Strengthening American Leadership in Digital Financial Technology,” which outlines the Trump administration’s proposed policy roadmap on digital assets (Report). The Report was mandated by Executive Order 14178, issued on …
In a significant step towards modernizing Bank Secrecy Act compliance, FinCEN and certain banking agencies are providing flexibility in “know your customer” requirements for banks.
The Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), …
The OCC has reversed recent changes to its bank merger policies through an interim final rule. Our client update is a refresher on the new state of play for Bank Merger Act applications to the OCC, which is a return …
In April 2025, the landscape of U.S. crypto regulation shifted significantly. Three of the country’s principal bank regulators – the Federal Reserve, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) – jointly …
The Federal Deposit Insurance Corporation (FDIC) is the U.S. agency responsible for insuring all bank deposits and facilitating all bank resolutions. Yet, as only one of three bank regulators, the agency relies on the Federal Reserve (Fed) and Office of …
New bank formation in the United States is at an all-time low, and Americans increasingly rely on non-bank financial technology companies (fintechs) to satisfy their financial services needs. Fintechs that do not operate through banks mostly operate outside the direct …
The announcement by Denver-based FirstSun Capital Bancorp and Seattle-based HomeStreet, Inc. on October 29 that the Federal Reserve and the Texas Department of Banking had asked them to withdraw their applications for approval of their pending merger illustrates the potential …
The DOJ, FDIC and OCC have revised their bank merger review standards. The new standards are a major shift for bank M&A and will require a careful, detailed analysis to evaluate the viability of any proposed transaction.
The Federal Deposit …
The Federal Deposit Insurance Corporation (FDIC) recently proposed and published a Federal Register notice for a proposed rule that would revise the agency’s Change in Bank Control Act (CIBCA) regulations. Specifically, the proposed rule would add a second layer …