Federal Savings Associations

On January 4, 2021, the OCC issued a proposed rule codifying standards governing a national bank’s or federal savings association’s investment in real estate used, or to be used, as bank premises.  Specifically, the proposed rule would revise 12 C.F.R. § 7.1024 in order to create a more transparent and consistent set of principles for evaluating the acquisition and use of  national bank and federal savings association premises.

Continue Reading OCC Proposes Rule Codifying Standards for Investment in Bank Premises

Today, the OCC released an interpretive letter concluding that national banks and federal savings associations (together, “banks”) may permissibly provide cryptocurrency custody services for customers.  The letter, written by Chief Counsel Jonathan Gould, describes custody of cryptocurrency as a modern form of the traditional banking activity of providing safekeeping and custody services, which the agency has previously permitted banks to conduct through electronic means.  The letter also “reaffirms the OCC’s position that national banks may provide permissible banking services to any lawful business they choose, including cryptocurrency businesses, so long as they effectively manage the risks and comply with applicable law.”

Continue Reading OCC Interpretation Paves Way for Banks to Custody Cryptocurrency

On November 30, 2018, the Federal Reserve requested comments on a new application form—the FR LL-10(e)—for savings and loan holding companies (“SLHCs”). The new form would replace Form H-(e), which was inherited from the Office of Thrift Supervision when the Dodd-Frank Wall Street Reform and Consumer Protection Act transferred supervisory authority for SHLCs