The OCC, Federal Reserve, and FDIC released updated guidance on model risk management, which rescinds and supersedes prior guidance to establish a more principles-based approach. Our visu...
Davis Polk partner and Financial Institutions practice co-head David Portilla, counsel Justin Levine and associate Andrew Rohrkemper authored “Tokenized Securities Have Capital Parity, ...
FinCEN and OFAC have taken steps to implement the AML/CFT and sanctions compliance obligations under the GENIUS Act, the most notable of which include compliance requirements applicable t...
Congress is considering enacting sweeping legislation that would ban large institutional investors from acquiring single-family homes. Although broad in scope, the proposal has important ...
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 ...
The OCC finalized a rule clarifying that national trust banks may engage in non-fiduciary activities but left open the question of whether a national trust bank must engage in a minimum a...
The Office of the Comptroller of the Currency issued a notice of proposed rulemaking that would change its supervisory appeals process. We compare the OCC proposal with the recently final...
The OCC proposed a rule that would eliminate any uncertainty as to whether national trust banks can engage in non-fiduciary activities. If adopted, the proposal would align language in th...
Davis Polk partners David Portilla and Gabe Rosenberg authored “Digital assets, banking and regulation: 2026 policy outlook” in IFLR. In the article, the authors note that “2026 wil...
