FRB Issues Policy Statement on Permissible Activities of State Member Banks While Denying Uninsured Crypto-focused Bank’s Membership Application
By EsqSocial Corporation 03/02/23
The Federal Reserve Board (“FRB” or “Board”) issued two seemingly related press releases late last week. The first announced the denial of the Federal Reserve membership application by Custodia Bank, a Wyoming special purpose depository institution. The second announced the issuance of a policy statement interpreting section 9(13) of the Federal Reserve Act (codified at 12 U.S.C. § 330) (“Policy Statement”) that provides a rebuttable presumption that the FRB would not allow a state member bank...
By: Cadwalader, Wickersham & Taft LLP