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In remarks delivered on January 16, 2026, to the American Bar Association Banking Law Committee meeting in Washington, DC, Comptroller of the Currency Jonathan Gould offered a strong critique of the current U.S. bank resolution planning framework, questioning both its legal foundations and its practical value after more than a decade of implementation.
On December 19, 2025, the Federal Reserve Board issued a Request for Information (“RFI”) on a proposed “Payment Account prototype.” The proposal responds to growing pressure from payments-focused institutions — particularly uninsured and novel charter entities — seeking faster, more predictable access to Federal Reserve payment rails that currently are only available with a Federal Reserve Bank master account.
On December 22, 2025, the Board of Governors of the Federal Reserve (the Board) issued a final rule that rescinded a 2023 policy statement and that in turn issued a new policy statement. In a memo submitted to the Board in November, Board staff explained that the 2023 policy statement was put into place at the time to address “particular sets of facts related to certain crypto-assets” and that the policy was intended to describe how the Board would approach regulating state member banks interested in engaging in such crypto-asset activities.
On December 12, 2025, the Office of the Comptroller of the Currency granted the conditional approval of five national trust bank charter applications involving crypto-focused institutions. The approvals include two de novo charters, First National Digital Currency Bank and Ripple National Trust Bank, and the conversion of three state trust companies, BitGo Bank & Trust, Fidelity Digital Assets, and Paxos Trust Company, into uninsured national trust banks subject to OCC supervision.
On December 16, 2025, the FDIC issued a notice of proposed rulemaking to implement the application and approval requirements under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”) for insured state nonmember banks and state savings associations seeking to issue payment stablecoins through a subsidiary. The proposal would add a new § 303.252 to the FDIC’s filing procedures in 12 C.F.R. Part 303, establishing a tailored, statute-driven process for obtaining FDIC approval to form and operate a “permitted payment stablecoin issuer” (“PPSI”) subsidiary.
On December 2, 2025 the House Financial Services Committee held an oversight hearing with leaders of the Federal Deposit Insurance Corporation, Federal Reserve Board, the National Credit Union Administration and the Office of the Comptroller of the Currency.
Earlier this week, the Federal Reserve Board (“FRB”) issued a press release on changes in supervisory approach consistent with Vice Chair of Supervision Michelle Bowman’s priorities, which she articulated in, among other places, a speech we covered in June when she was just confirmed to the Vice Chair position.
On November 5, 2025, the Federal Reserve Board (“FRB”) finalized changes to its supervisory rating framework for large bank holding companies. The finalized LFI framework is substantially similar to the proposal issued in July.
Last week, on October 7, 2025, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the “Agencies”) issued two joint notices of proposed rulemaking (NPRs). First is an NPR to codify the elimination of reputation risk from their supervisory programs the “Reputation Risk NPR”). Second, is an NPR to define the term “unsafe and unsound practice” (the “Safety and Soundness NPR”).
As we previously reported, on August 29, the Federal Reserve Board (“FRB”) announced the individual capital requirements for all large banks, effective on October 1. This announcement follows the June announcement on the results of the supervisory stress test (also known as the Dodd-Frank Act Stress Test or DFAST, as these tests are required by Section 165 of the Dodd-Frank Act), which assesses whether banks are sufficiently capitalized to absorb losses during a severe recession.