Title

The OCC Moves on Digital Banking Activities and Regulatory Modernization
Client Memorandum

Created date

6/9/2020

Acting Comptroller Brian Brooks is moving quickly to make his mark on the digital activities of national banks and to modernize OCC regulations, especially those that intersect with fintech, with two releases that cover a wide range of digital and other topics.  The proposals are directly relevant to national banks and federal savings associations, but should be of interest to a broader range of banking organizations both because OCC regulations on bank powers have implications for many state banks under state wild card statutes and because the proposals may spur other U.S. banking regulators, including the Federal Reserve and the FDIC, to update their own rulebooks.