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Yesterday, U.S. Representatives Young Kim (R-CA) and Sam Liccardo (D-CA) introduced the Payments Access and Consumer Efficiency Act of 2026 (PACE Act). The bill would create an optional federal framework for large state‑regulated payment companies, giving qualifying firms Office of the Comptroller of the Currency (OCC) supervision and potential direct access to Federal Reserve payment rails, in exchange for bank‑like prudential and customer‑protection standards. It is an early‑stage proposal with uncertain prospects but significant implications for nonbank payments and bank–fintech partnerships.

The U.S. Department of the Treasury has issued a notice of proposed rulemaking (NPRM) to implement the broad-based principles set out in the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act for determining when a state-level regulatory regime for “state qualified payment stablecoin issuers” is “substantially similar” to the federal regulatory framework. That determination is the gateway for state-chartered, nonbank stablecoin issuers with up to $10 billion in outstanding stablecoins to operate primarily under state oversight rather than as federally supervised “permitted payment stablecoin issuers.” Comments will be due 60 days after publication in the Federal Register.

On December 5, 2025, the Office of the Comptroller of the Currency (OCC) issued OCC Bulletin 2025-45, “Commercial Lending: Venture Loans to Companies in an Early, Expansion, or Late Stage of Corporate Development,” which rescinds OCC Bulletin 2023-34, “Commercial Lending: Venture Loans to Companies in an Early, Expansion, or Late Stage of Corporate Development.” The OCC’s message in issuing the new bulletin to replace the prior bulletin is straightforward: the agency does not want to discourage prudent venture lending. At the same time, it expects banks to recognize that venture loans carry materially higher default risk than conventional commercial loans and to manage that risk through disciplined underwriting, realistic risk ratings, and appropriate reserves.[1]

On March 5, 2026, the IRS issued proposed regulations (the Proposed Regulations) setting forth an alternative process for digital asset brokers to obtain consent from customers to receive Form 1099-DA statements electronically. This alternative process provided in the Proposed Regulations is meant to alleviate administrative tax compliance burdens for digital asset brokers. The IRS and Treasury also issued Notice 2026-4, requesting public comments on whether (i) less burdensome consent procedures should be implemented for other payee statements, including Form 1099-B, and (ii) the list of forms permitted on a Form 1099-B composite statement should include Form 1099-MISC for the purpose of reporting “staking rewards,” (i.e., additional units of cryptocurrency granted in exchange for holders locking up assets held in native cryptocurrency to help validate and secure the blockchain).

On February 11, the National Credit Union Administration (NCUA) released a proposed rule to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the GENIUS Act) for federally insured credit unions (FICUs). Under the proposal, credit unions cannot issue payment stablecoins directly. Instead, only NCUA‑licensed “permitted payment stablecoin issuers” (PPSIs) that are subsidiaries of FICUs would be allowed to issue payment stablecoins, and FICUs would be limited to investing only in PPSIs licensed by the NCUA.

On January 29, the U.S. Senate Committee on Agriculture, Nutrition, and Forestry (AG Committee), led by Chairman John Boozman (R‑AR), advanced S. 3755, the Digital Commodity Intermediaries Act (DCIA), on a party-line vote. The DCIA builds on the bipartisan, House-passed CLARITY Act to create a federal registration and compliance regime for key digital asset intermediaries. The DCIA also would provide a clear legal definition of “digital commodities” and establish a spot market digital commodity intermediary regulatory regime with the Commodity Futures Trading Commission (CFTC). In the press release, Chairman Boozman framed the vote as “a critical step toward creating clear rules for digital asset markets” that protect consumers while allowing innovation to thrive.

In 2025, the U.S. digital asset landscape evolved more dramatically than in any year since the industry’s inception. A pro‑innovation White House, an active Congress, and key regulators — including the U.S. Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), the Office of the Comptroller of the Currency (OCC), the Department of…

In today’s rapidly evolving digital landscape and expanded threat landscape, financial institutions feel at war and are under increasing pressure to balance innovation, data privacy, and regulatory demands. AI is accelerating that complexity, reshaping how organizations manage sensitive information and comply with a rapidly shifting legal environment.

On November 20, U.S. Senate Agriculture Committee Chairman John Boozman (R‑AR) and Senator Cory Booker (D‑NJ) released a new bipartisan discussion draft to create a federal spot‑market regime for “digital commodities” under the Commodity Futures Trading Commission (CFTC). The proposal, which expands upon the CLARITY Act approved by the House in July, would give the CFTC exclusive jurisdiction over cash and spot trading in covered non‑security crypto tokens, establish registration frameworks for exchanges, brokers, and dealers, impose listing and public‑information standards, require qualified custody and strict segregation of customer assets, enhance retail protections, and clarify bankruptcy treatment of customer property.

Federal banking regulators previewed near-term rulemaking plans that will shape the fintech landscape. The Federal Deposit Insurance Corporation (FDIC) expects to issue a stablecoin licensing proposal “before the end of the year,” and the FDIC reiterated that “a deposit is a deposit” even when tokenized. Separately, the Federal Reserve is targeting the fourth quarter of 2026 for operational rollout of “skinny” master accounts to widen access to payment rails for eligible depository institutions.