The New York DFS issued new guidance regarding a covered entity’s reliance on an affiliate’s cybersecurity program. The guidance explains DFS’s view that, when a covered entity reli...
The Federal Reserve, FDIC and OCC jointly issued a due diligence guide for community banks for assessing potential relationships with fintechs. Our client update examines the implication...
The FDIC announced a modified approach to implementing its insured depository institution (IDI) resolution planning rule for IDIs with $100 billion or more in total assets. Our client upd...
The FDIC has issued a final rule to formalize longstanding expectations it has had for the parent company of a new industrial loan company (ILC). The FDIC adopted the proposed rule issue...
The OCC has issued an interpretive letter confirming that national banks may take deposits that serve as reserves for fiat currency-pegged stablecoins. The letter continues the series of ...
The SEC has finalized rules that will replace Guide 3, the industry guide for banking organizations. The final rules eliminate a number of the requirements under Guide 3, which now appea...
The Fed has announced details of the FedNow Service, a 24x7x365 instant payments service slated for initial launch in 2023 or 2024. This Davis Polk memo describes the big picture of the U...
The Federal Reserve’s recent updates to its regulations on confidential supervisory information and availability of information under the Freedom of Information Act include several mean...
The Office of the Comptroller of the Currency issued an interpretive letter confirming that national banks and federal savings associations may provide cryptocurrency custody services. Th...
The Federal Reserve has taken temporary measures (and has published FAQs) to (1) lift the net debit cap on and waive fees for daylight overdrafts for financially sound depository institut...
