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On Monday, September 21, 2020, the Office of the Comptroller of the Currency issued an interpretive letter on the authority of national banks and federal savings associations to hold stablecoin reserves. That same day, the Securities and Exchange Commission’s Strategic Hub for Innovation and Financial Technology issued a statement on the OCC’s interpretive letter. While not an official joint statement, the federal agencies were clearly aligned as FinHub’s statement on the OCC Interpretive Letter was posted on its website before the OCC published its letter.…
Continue Reading OCC and SEC’s FinHub Issue Guidance on Stablecoins

As a show of continued interest in the development of cryptoasset solutions, Senator Mike Crapo (R-ID), Chairman of the Senate Committee on Banking, Housing and Urban Affairs, recently sent a letter to Acting Comptroller of the Currency Brian Brooks. Chairman Crapo’s letter requested an update on findings of the Office of the Comptroller of the Currency and information regarding next steps the OCC intends to take with respect to blockchain and distributed ledger technology.…
Continue Reading Senate Banking Committee Shows Continued Interest in Cryptoassets

Effective August 1, 2020, Louisiana adopted the Virtual Currency Business Act. In doing so it becomes the second state after New York to require certain operators of virtual currency businesses to obtain a virtual currency license in order to conduct business in the state. The Act is perhaps notable not so much for the conduct it covers, but rather the very broad classes of persons and businesses granted exemptions from regulation.…
Continue Reading Louisiana Adopts Virtual Currency Business Act

On July 22, 2020, the Office of the Comptroller of the Currency published an interpretive letter clarifying the authority of national banks to provide cryptocurrency custody services for customers. This latest guidance is just one of many recent developments coming out of the OCC focused on modernizing the regulatory framework at the national level. …
Continue Reading OCC Releases Guidance on the Authority of National Banks to Provide Cryptocurrency Custody Services