OCC Interpretive Letter 1192 Confirms National Bank Act Preemption

Understanding Regulation CC and Funds Availability

Joe Silvia explains the The Expedited Funds Availability Act, implemented by the Federal Reserve as Regulation CC, which applies to all insured banks and credit unions and requires them to make funds deposited into transaction accounts available for withdrawal on defined availability schedules.

Implementing the GENIUS Act's Customer Identification Program Requirement

Joe Silvia discusses the proposed rule [https://www.federalregister.gov/documents/2026/06/22/2026-12460/permitted-payment-stablecoin-issuer-customer-identification-program] to implement the GENIUS Act's "directives to treat permitted payment stablecoin issuers (PPSIs) as financial institutions under the Bank Secrecy Act and to require issuers to maintain an effective customer identification program (CIP).

OCC Interpretive Letter 1192 Confirms National Bank Act Preemption

Joe Silvia explains the significance of OCC Interpretive Letter 1192 [https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2026/int1192.pdf], which confirms that the National Bank Act preempts state law and the bank in question "may engage in its federally authorized activities nationwide and is not required to hold a state money transmitter license or satisfy a state law exemption."

Traditional Banking Institutions to Launch Tokenized Deposit Network

Joe Silvia examines the plans announced by the largest U.S. banks and financial institutions to launch a tokenized deposit network next year in response to crypto companies and stable coins taking an increasing share of core deposits and removing liquidity from the traditional, regulated banking system.

Vice Chair Michelle Bowman's Testimony on the Federal Reserve Supervision and Regulation Report

Joe Silvia reviews and analyzes the recent testimony of Vice Chair for Supervision Michelle W. Bowman [https://www.federalreserve.gov/aboutthefed/bios/board/bowman.htm] before the Committee on Financial Services, U.S. House of Representatives on the June 2026 release of the Federal Reserve Supervision and Regulation Report. Vice Chair Bowman's remarks covered "current banking conditions, regulatory and supervisory reforms implemented since the Committee's last prudential regulator hearing, and our path forward as we continue to promote the safety, soundness, and stability of the U.S. financial system while supporting economic growth."