Partner
Norton Rose Fulbright US LLP
Tim Byrne is a Partner based in New York. He advises major financial institutions on the bank regulatory aspects of financial products and corporate transactions.
Tim advises on a range of other issues from anti-money laundering enforcement matters to bank insolvency issues, capital requirements and outsourcing and vendor management. He is the immediate past chair of the Securities, Capital Markets and Derivatives Subcommittee of the American Bar Association Banking Law Committee.
Recent Articles & Comments
The OCC’s Interpretive Letter is another step in expanding the regulatory authority of banks to engage in crypto-related activities. By determining that riskless principal crypto-asset transactions are incidental to the business of banking, the OCC continues to build on its recent crypto-related guidance. Specifically, see which confirmed that national banks may pay blockchain network fees and hold the necessary inventory of crypto-assets as principal to facilitate those payments. The…
The OCC’s interpretive letter is another step in expanding the regulatory authority of banks to engage in crypto-related activities. Although the OCC’s current view is that the activities described in the letter are incidental to the business of banking (rather than a part of the business of banking), the OCC can be expected to continue to expand the authority that national banks have to engage in crypto activities.
The OCC’s action is also relevant to state banks for two…
Ms. Bowman's remarks further reinforce expectations that significant regulatory changes will be made as a result of the EGRPRA process, which in the past has not resulted in significant changes to the bank regulatory framework.
This is a significant rolling back of a prudential regulatory requirement. This initiative will benefit the largest banks, but it also establishes an expectation that the OCC is thinking seriously about outright repeal of various regulatory requirements. In this regard, in a March 2025 comment letter submitted as part of the EGRPRA regulatory review process, a banking industry trade association had recommended that these guidelines be rescinded. The OCC’s action indicates that the industry’s…