September 19, 2021

Volume XI, Number 262

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September 17, 2021

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Better Than Under the Mattress - OCC Opens the Door to Cryptocurrency Custody

The Office of the Comptroller of the Currency (OCC) recently published a letter clarifying the authority of national banks and federal savings associations to provide cryptocurrency custody services for customers.  National and state banks and thrifts have long provided safekeeping and custody services, including both physical objects and electronic assets. In the letter, the OCC recognized that providing cryptocurrency custody services, including holding unique cryptographic keys associated with cryptocurrency, is a modern form of traditional bank activities related to custody services. The OCC also noted crypto custody services may extend beyond passively holding "keys." The OCC recognized that, as the financial markets evolve, there will be an increasing need for banks and other service providers to use technology in innovative ways to serve the need of their customers.

© Polsinelli PC, Polsinelli LLP in CaliforniaNational Law Review, Volume X, Number 223
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About this Author

Richard Levin Polsinelli Fintech Attorney
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Richard Levin is the Chair of Polsinelli’s Chambers rated FinTech and Regulation Practice.  He brings his experience as a senior legal and compliance officer on Wall Street and in London to bear in advising clients on corporate, securities and regulatory issues. A problem-solver by nature, his practice focuses on helping financial services and technology (FinTech) clients identify and address regulatory issues as they build their businesses.

The FinTech sector is...

303.583.8261
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David Allred believes that excellent client service begins with strong relationships. David is a member of the Banking and Financial Institutions practice and represents both publicly traded and privately held banks at all stages of the business cycle, from formations to a mature business. As an accountant and an attorney, David brings a unique perspective to providing corporate advice to clients in ever-changing regulatory environments. He has served banks on a broad range of complex legal issues including: 

  • Mergers and acquisitions
  • ...
720.931.1193
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