by Mark Chorazak and Donna Parisi
On August 16th, 2022, the Fed announced a new procedural requirement for banks seeking to engage in crypto activities. Going forward, a bank must provide formal notice to its lead supervisory contact at the Fed “prior to engaging in any crypto-asset-related activity.” This notice requirement applies to all bank holding companies, savings and loan holding companies, and state-chartered member banks. The term “crypto-asset-related activity” includes, at a minimum, crypto-asset safekeeping and traditional custody services, ancillary custody services, facilitation of customer purchases and sales of crypto-assets, loans collateralized by crypto-assets, and issuance and distribution of stablecoins.