Document Directory

This table lists and links to the markdown documents available on this site, sorted by document date, with AI-generated titles and summaries to help you find the documents you are interested in. Caution: While we used various methods to promote the accuracy of the AI-generated metadata, only a subset has been reviewed by human experts. Look at it as a starting point for your research, not the final word.

Title (AI-generated)	Date	FDIC Unit	Summary (AI-generated)
Crypto Platform Compliance Inquiry 2018	2018-12-10	New York Regional Office	This document is a letter from the FDIC's New York Regional Office to a bank's Board of Directors regarding the bank's announced digital payments platform called XXXXX. The FDIC acknowledges reviewing the bank's previous correspondence and participating in a conference call about the program. The letter requests specific information from the bank, including due diligence and analysis regarding whether the program is permissible for a national bank under Part 362 of FDIC Rules and Regulations, whether the products are securities under federal securities laws, whether they are virtual currencies under IRS Notice 2014-21, and all customer disclosures related to the program. The FDIC also requests a meeting with the bank to discuss the program and sets a deadline of December 28, 2018 for the requested materials.
FDIC Requests Details on Crypto Custody	2021-04-30	Atlanta Regional Office	This document is a response from the FDIC's Atlanta Regional Office to a bank's request for non-objection or approval to provide cryptocurrency custody services. The FDIC states it cannot provide feedback without additional information, specifically requesting details about the bank's expertise and risk management framework for overseeing cryptocurrency custody activities. The FDIC recommends the bank obtain a declaratory statement from state authorities regarding the permissibility of the proposed services and whether they constitute fiduciary activities under state law. The letter also notes that the bank's additional contemplated services (cash custody, lending against cryptocurrency, and settlement services) lack sufficient detail for review, and suggests addressing these after completing review of the custody services.
NYRO Reviews Bank's Crypto Plans	2021-10-04	New York Regional Office	This letter from the FDIC's New York Regional Office responds to a bank's presentation and correspondence regarding potential cryptocurrency activities. The FDIC states that the descriptions of the bank's proposed crypto products—including warehouse loans collateralized by cryptocurrencies, merchant acquiring services, custody services, staking and exchanging services, and a stablecoin—were not sufficiently detailed to determine if they fall within the scope of referenced OCC Interpretive Letters and Conditional Approvals. The FDIC notes that the Acting Comptroller of the Currency is reviewing these interpretive letters, and reminds the bank that any activities must be permissible under state laws and regulations, with appropriate risk management practices in place before offering such products. The FDIC requests that the bank share state regulatory views and planning documentation well in advance of implementation.
FDIC Requests Info on Crypto Platform	2021-12-02	New York Regional Office	This letter from the FDIC to a bank's Board of Directors acknowledges the bank's plans to begin testing a new digital payments platform and requests extensive information following the FDIC's review of materials and conference calls about the program. The FDIC requests due diligence, analysis, and opinions on multiple regulatory matters including whether the platform's activities are permissible under FDIC regulations and national banking laws, whether the platform's token is a stablecoin or security, potential CFTC jurisdiction, FDIC deposit insurance availability, and IRS reporting requirements. The letter also requests all agreements and disclosures to be provided to users, information about BSA/AML/OFAC monitoring, cybersecurity protocols, third-party vendor oversight, and policies governing the creation and management of the platform's tokens.
Bitcoin Finder Service Guidelines	2022-02-09	Dallas Regional Office	This letter from the FDIC's Dallas Regional Office addresses a bank's plan to enter into an agreement with a third party to allow customers to purchase or sell Bitcoin. The bank would act as a finder, with customers' Bitcoin transactions flowing through their bank accounts, but the bank would have no direct exposure to Bitcoin. The letter references the November 23, 2021 Joint Statement on Crypto-Asset Policy Sprint Initiative issued by federal banking agencies, which is attached to the letter. The FDIC advises the bank that regulatory clarity on crypto-asset activities is forthcoming in 2022, and that the bank may need to file appropriate notices or applications to continue the service. The letter recommends that the bank ensure flexible commitments to the program, monitor third-party and reputational risks, provide clear customer disclosures that Bitcoin is not FDIC insured, update IT and BSA functions, and develop exit strategies.
Bank's 2021 Performance and Crypto Activities	2022-02-15	Unknown	This memorandum summarizes a discussion between FDIC representatives and bank officials regarding the bank's condition and operations. The document notes that the bank has digital asset customers, and the FDIC raised concerns about BSA/AML recommendations related to these customers. The FDIC emphasized the need for the bank to better understand and justify the cash activity involving these digital asset customers, citing the Customer Due Diligence Rule and Suspicious Activity Rule as the legal basis for their recommendations. The FDIC clarified they were not asking the bank to exit these customer relationships but to implement enhanced due diligence for these higher-risk accounts. The bank committed to take further action to better understand the underlying cash transactions of their digital asset customers.
Bank's Blockchain Network Concerns	2022-03-11	Dallas Regional Office	This letter from the FDIC Regional Director to a bank's Board of Directors addresses the bank's announced membership in a blockchain network. The FDIC notes that federal regulators participated in a conference call with the bank's management and understands the network is drafting operating rules for transactions on its blockchain network. The letter expresses that the FDIC has "questions and concerns" about the information provided thus far and expects the bank to address these concerns before implementation to ensure safe and sound operations. The FDIC indicates it will submit separate documentation with questions that have not been satisfactorily addressed and additional questions and document requests. The letter references Section 39 of the Federal Deposit Insurance Act and Part 364 of the FDIC Rules and Regulations.
Bank's Bitcoin Product Proposal	2022-04-01	Dallas Regional Office	This document summarizes a Teams call between FDIC officials and bank management regarding the bank's proposed crypto-related product. The bank was asked to pause all crypto asset-related activity in prior correspondence. During the meeting, bank management described their planned product that would allow customers to buy, sell, and hold Bitcoin through a third-party service, with Bitcoin held in a custodian account belonging to customers. The bank explained that Bitcoin would never touch the bank's balance sheet, no "wallets" would be offered, and appropriate disclosures would indicate Bitcoin is not FDIC insured. Management discussed their due diligence, including a risk assessment covering various risk categories, with compliance, operational, strategic, and reputational risks identified as high and medium risks. The bank indicated they were pursuing this product to remain competitive with Fintech companies and other banks.
Bank's Bitcoin Service Discussion	2022-04-04	Kansas City Regional Office	This memo documents a call between FDIC representatives and bank management regarding the bank's potential relationship with a third party to offer Bitcoin services to customers. The bank was in the testing and risk assessment stage for offering customers the ability to buy, sell, and hold Bitcoin. Bank management noted they had identified approximately XXXXX digital currency transactions by their customers totaling XXXXX. The bank had established an executive committee overseeing the initiative and involved legal counsel in the risk assessment. The proposed activity would be limited to Bitcoin transactions only, with customers required to sign an acknowledgment that transactions would be with the third party rather than the bank. The memo indicates the bank would not proceed with the offering until they could ensure the activities would be conducted as agent and that the FDIC would consider them legally permissible.
FDIC Emails Discuss Bank's Crypto Service Proposal	2022-04-05	Kansas City Regional Office	This document contains an email exchange between FDIC personnel regarding a bank's preliminary exploration of offering cryptocurrency services. The bank is considering a service that would allow customers to purchase Bitcoin and eventually other cryptocurrencies, with the bank earning fees for facilitating transactions. The FDIC case manager informed the bank representative that without specific implementation details, it was difficult to provide definitive guidance, noting the lack of clear-cut laws and guidance on digital assets. The case manager advised that such activities would require detailed product understanding, robust policies and procedures, and possibly additional capital. The discussion included considerations about risk allocation, monitoring the financial position of the third-party provider, transaction clearing processes, and potential margin requirements. The case manager also mentioned that depending on the final proposal, it might need review by the FDIC's Washington office.
Bank's Crypto Pilot Program Discussion	2022-04-15	Dallas Regional Office	This document summarizes an informal meeting between an FDIC Field Supervisor and a bank president regarding the bank's potential involvement in crypto-related activities. The bank president indicated that the institution is part of a BETA Pilot with an unnamed provider but has not conducted any transactions yet, and implementation could take up to a year or might not happen at all. The president acknowledged awareness of a recent FIL (Financial Institution Letter) from April 7th but did not notify the FDIC because the activity was not yet operational. The Field Supervisor advised the president to keep the CM/RE and another entity informed of plans to proceed and noted that the FDIC is examining these types of services from a nationwide perspective, with additional communication likely forthcoming.
Bank's Crypto Activities Inquiry	2022-04-18	San Francisco Regional Office	This letter from the FDIC's Division of Risk Management Supervision follows up on a bank's response to FIL-16-2022 regarding "Notification and Supervisory Feedback Procedures for FDIC-Supervised Institutions Engaging in Crypto-Related Activities." The FDIC requests additional information about the bank's crypto-related activities, specifically asking four questions about the bank's relationship with an ISO (presumed to be an Independent Sales Organization), including a request for the contract between the bank and ISO customer, details about services provided, BSA and Compliance oversight, and information about any omnibus account usage and how FDIC deposit insurance applies. The letter requests a written response by May 20, 2022.
Bank's Crypto Customer Due Diligence	2022-04-22	Unknown	This memorandum documents a discussion between FDIC representatives and bank management regarding the bank's digital asset customers. The bank provided an update on its analysis of CTR data for digital asset customers, particularly focusing on customers making large cash deposits into bitcoin kiosks. Bank management expressed uncertainty about whether these transactions were suspicious and what further actions were required. FDIC representatives emphasized the need for comprehensive customer due diligence (CDD) and enhanced due diligence (EDD), noting numerous red flags in the transactions. The FDIC clarified they were not requiring the bank to exit these relationships but wanted the bank to conduct more thorough due diligence and present findings to the board. The bank agreed to conduct additional CTR reviews, undergo a BSA audit, and present findings to its board within the coming months.
Crypto Program Governance Concerns	2022-04-25	New York Regional Office	This letter from the FDIC to a bank's Board of Directors contains extensive questions about the bank's participation in a blockchain-based program referred to as "XXXXX." Following a February 2022 meeting with regulatory agencies, the FDIC is requesting detailed information about the program by June 9, 2022. The attached questionnaire covers eight major areas - governance and structure, classifications, accounting, exposure to other members, risk management and controls, settlement, use cases, and consumer protection. The questions seek information about the blockchain protocol, smart contracts, transaction validation, reserve requirements, risk mitigation strategies, settlement processes, and consumer protections. The FDIC cites FIL-16-2022, which requires institutions to provide information for assessing safety and soundness implications of such activities, and references Section 39 of the Federal Deposit Insurance Act and Part 364 of FDIC Rules and Regulations.
Bank's Future Crypto Plans Discussed	2022-05-11	Dallas Regional Office	This memorandum documents a discussion between an FDIC Case Manager and a bank's Executive Vice President/Chief Risk Officer regarding the bank's plans for digital asset activity. The bank is not currently engaged in any digital or crypto-asset activity, though senior management has interest in pursuing such activities in the future. The bank indicated research on potential companies to engage with would likely begin in the current year, with no contracts expected until 2023 at the earliest. The FDIC Case Manager directed the bank to FDIC FIL-16-2022, "Notification of Engaging in Crypto-Related Activities," and informed the bank of the requirement to submit information to the DALRO prior to engaging in any crypto-related activities.
Email Exchange on Third-Party's Meeting Request	2022-05-17	Unknown	This document contains an email exchange regarding a bank's notification to the FDIC about its relationship with a crypto-related entity. The supervisory examiner forwards a message from a bank representative who confirms they submitted a disclosure about their investment in a crypto company. The bank representative inquires about the best way for the crypto company to connect with regulatory agencies to discuss crypto/digital asset matters and establish a relationship. The email references an attached notification that was submitted on May 3rd, though the attachment is not included in the document.
Bank's Bitcoin Finder Service Review	2022-05-18	Dallas Regional Office	This memo documents a follow-up call between an FDIC Case Manager and a bank's President/CEO regarding the bank's Bitcoin finder service. The service had gone live and processed 80 transactions totaling $92,000, with 70 purchases and 10 sales. Transaction details included approximately 36 users (some being bank employees testing the service), with one customer responsible for about $50M in purchases. The bank reported no complaints, technology issues, or unusual customer activity. The FDIC representative informed the bank that it might be asked to suspend the service while issues are considered at a national level. The memo includes a spreadsheet of the Bitcoin transactions showing transaction IDs, buy/sell status, amounts, and order information.
May 2022 Crypto Activities Discussion	2022-05-26	Unknown	This document summarizes an interim contact between FDIC examiners and bank management. During the meeting, the bank's President mentioned discussions about potentially engaging in crypto activities to "stay ahead of the curve." In response, the FDIC examiner informed the management team about recently released guidance requiring banks to discuss any crypto activities with regulatory agencies before engaging in such activities. The contact also covered the bank's succession planning and core processing contract considerations.
FDIC Letter Requests Crypto Activity Details by July 15	2022-05-31	Chicago Regional Office	This letter from the FDIC to a bank's Board of Directors acknowledges receipt of the bank's correspondence about its cryptocurrency activities and requests additional information for further review. The FDIC asks for specific documents including a questionnaire, updated risk assessment, policy, and procedures related to holding cryptocurrency in a directed trust. The letter also requests details about an account containing cryptocurrency held by the Wealth Management Department, including the type of cryptocurrency, the bank's authority over it, security controls for private keys/passwords, plans for third-party partnerships, and cryptocurrency insurance coverage. The FDIC provides instructions for submitting the requested information and copies the Federal Reserve Bank of Cleveland on the communication.
Extension Granted for Crypto Inquiry	2022-06-10	New York Regional Office	This document is a letter from the FDIC's New York Regional Office to a bank, approving the bank's request for an extension of time to respond to questions related to the bank's participation in a redacted program. The original FDIC questions were transmitted on April 25, 2022, with responses initially requested by June 9, 2022. The bank had prepared responses but requested an extension until June 20, 2022 to allow their Audit and Risk Committee to review and approve the responses. The FDIC approved this extension request and instructed the bank to provide prior notice if they are unable to meet the new deadline.
Bank's Digital Asset Entry Evaluation	2022-06-14	Dallas Regional Office	This letter from the FDIC Regional Director responds to correspondence and a meeting with a bank regarding its potential entrance into digital asset activities. The bank is considering offering small dollar loans secured by digital assets, establishing digital wallets with third-party platforms, and exploring arrangements to allow customers to purchase, sell, and hold digital assets through the bank's online banking platform. The FDIC requests extensive information about the proposed activities, including details on product structure, BSA/CFT implications, IT impacts, valuation methodologies, board-approved policies, wallet structures, vendor due diligence, personnel responsibilities, collateral processes, risk assessments, strategic plans, consumer disclosures, legal opinions on permissibility under Federal and State law, and analysis regarding SEC Staff Accounting Bulletin No. 121. The bank is asked to provide this information within 60 days.
FDIC Crypto Notification Discrepancy Discussion	2022-07-01	New York Regional Office	This email discusses a crypto notification from a bank, noting a discrepancy in the tracking system where the activity was marked as not within the FIL scope, while the letter suggests it is in scope. The sender requests that the recipients change the tracking system to indicate the activity is within scope and add it as an associated activity of "Facilitating Customer Buy/Sell" with a third party. The email mentions that a template letter and request list for this type of activity is being developed and will be distributed to regions soon.
SFRO Recommends Crypto Activity Notification	2022-07-07	San Francisco Regional Office	This memorandum from the FDIC's San Francisco Regional Office (SFRO) recommends that a prospective banking relationship between a bank and a cryptocurrency exchange should be considered "crypto-related activities" under FIL-16-2022, requiring formal notification to the FDIC. The document details discussions with bank management about the proposed relationship, which would involve the bank holding customer funds for the exchange in a non-interest bearing account and maintaining a separate operating account for the exchange. The SFRO expresses concern that bank management lacks robust understanding of the size, complexity, and risks of the proposed activities, particularly noting that management had not previously considered that digital asset secured loan disbursements could be processed through the accounts. The memo includes details about the proposed account structure, anticipated sources of funds, and the bank's planned oversight of the relationship.
Bank's Bitcoin Custody Concerns	2022-07-13	Chicago Regional Office	This memorandum documents the FDIC's review of a bank's cryptocurrency-related activities involving a trust account holding Bitcoin. The document outlines concerns regarding the bank's policy, which does not specify cryptocurrency custodian expectations or requirements for wallet key maintenance and security. The memo notes that the trust account was funded with Bitcoin shares custodied at a cryptocurrency exchange, with the bank serving as trustee and accessing the cryptocurrency through a password rather than traditional keys. The document includes potential follow-up questions and documentation requests regarding password security controls, clarification of the bank's custodial role, details about cryptocurrency access permissions, future custodian arrangements, and risk assessment documentation. The memo references a meeting between FDIC officials to discuss these items.
Bialosky Assigned to Crypto Case	2022-07-21	San Francisco Regional Office	This document contains an email exchange regarding a bank's crypto-related activities. The bank is described as "not heavily involved in crypto-related activity" with the bank's President stating intentions to reduce deposits related to crypto. According to information provided in October 2021, the President emphasized that the bank has no intention or strategy to seek out or attract digital asset related customers and is actually reducing these types of customers to become a "plain vanilla, traditional style" bank. The document notes that customers with crypto-related activity were onboarded in 2020 through a relationship with a bank employee who later resigned. The bank has three high-risk customers potentially related to digital currency, blockchain, or crypto, though specific details about these customers are redacted. The document also includes a table showing large depositor funding concentration.
July 2022 Crypto Conference Call	2022-07-26	New York Regional Office	This memorandum documents a conference call between FDIC representatives and bank trust department management regarding crypto-related holdings in client accounts. The call was held to clarify information about crypto assets reported in previous correspondence and to request retention letters. The bank disclosed that three clients hold crypto-related assets, which had been inadvertently underreported in previous communications. The FDIC requested retention letters to substantiate that these were client-directed purchases being retained with client direction. The bank subsequently provided these letters for all three clients. The memo includes a table summarizing the crypto-related assets held in client accounts, noting that all accounts have been negatively impacted by the recent market environment.
July 2022 Crypto Assets Call	2022-07-26	New York Regional Office	This memorandum documents a conference call between FDIC and bank trust department management regarding crypto-related holdings in client accounts. The bank clarified that three clients hold four crypto-related assets, which were previously incompletely reported to the FDIC. The FDIC requested retention letters to substantiate that these were client-directed purchases being retained with client direction. The bank subsequently provided these letters for all three clients, with some follow-up required regarding an incorrectly dated letter. The memo includes a table summarizing the crypto-related assets held in client accounts, noting that all accounts have been negatively impacted by the recent market environment. Email correspondence between the bank and FDIC regarding the retention letters is also included.
Response to Bank's Crypto Services Notification	2022-08-08	Dallas Regional Office	This letter from the FDIC acknowledges receipt of a bank's notification regarding its intent to offer customers the ability to buy, sell, and hold Bitcoin and Ethereum through its digital and mobile banking platforms in conjunction with a third party. The notification was submitted in response to FIL-16-2022, "Notification of Engaging in Crypto-Related Activities," which requested that FDIC-supervised institutions notify the FDIC about crypto-asset activities. The FDIC requests additional information from the bank by October 3, 2022, to assess the safety and soundness, consumer protection, and financial stability implications of these activities, noting that after reviewing this information, the FDIC will determine if additional information is needed and will provide supervisory feedback as appropriate.
FDIC Letter on Crypto Banking Inquiry	2022-08-17	San Francisco Regional Office	This letter from the FDIC responds to a bank's inquiry about a prospective banking relationship with a crypto-asset exchange company. The FDIC requests that the bank provide formal notification as required by FIL 16-2022 if it intends to pursue the activities discussed previously. The letter outlines extensive information requirements including details about how the relationship fits into the bank's strategic plan, draft contracts, disclosure information, structure of the proposed omnibus for-benefit-of account, anticipated account size and activity, capital management plans, staffing capacity, AML/CFT profile changes, information security controls, deposit insurance disclosures, customer dispute resolution processes, monitoring of marketing materials, due diligence activities, and engagement letters for consulting work related to the relationship.
FDIC Requests Information to Assess Bitcoin Services	2022-08-22	Chicago Regional Office	This document is a letter from the FDIC's Chicago Regional Office to a bank's Board of Directors regarding the bank's notification of intent to offer customers the ability to buy, sell, and hold Bitcoin through its digital and mobile banking platform. The letter acknowledges receipt of the bank's notification in accordance with FIL-16-2022 (Notification of Engaging in Crypto-Related Activities) and requests extensive information to assess the safety and soundness, consumer protection, and financial stability implications of the proposed crypto-asset activities. The letter includes a detailed 25-item request list covering strategic planning, risk assessments, vendor management, legal analysis, policies and procedures, consumer disclosures, transaction flows, and other operational aspects of the proposed Bitcoin services. The FDIC indicates it will provide supervisory feedback after reviewing the requested information.
FDIC-Bank Emails on Crypto Depository Services	2022-08-22	San Francisco Regional Office	This document contains email correspondence between a bank and the FDIC regarding the bank's interest in providing services to a cryptocurrency exchange. The bank initially inquired about offering traditional commercial banking services to a crypto platform, and later explored establishing an omnibus FBO (For Benefit Of) deposit account for the platform's customers' U.S. dollars. The bank sought clarification on whether FDIC Financial Institution Letter (FIL) on "Notification of Engaging in Crypto-Related Activities" applied to their situation, and requested guidance on examination expectations, vendor management requirements, and regulatory considerations. The FDIC case manager referenced the April 7 FIL that requires FDIC-supervised institutions to notify the FDIC of engagement in crypto-related activities, requested more details about the proposed relationship, and noted that the bank should consider various crypto-related risks.
Bitcoin Services Assessment Request	2022-09-01	New York Regional Office	This letter from the FDIC's New York Regional Office to a bank acknowledges receipt of the bank's notification about its intent to offer customers the ability to buy, sell, and hold Bitcoin through its digital and mobile banking platform in conjunction with a third party. The notification was submitted in response to FIL-16-2022, "Notification of Engaging in Crypto-Related Activities." The FDIC requests that the bank provide information listed in an attached document by October 31, 2022, to allow the FDIC to assess the safety and soundness, consumer protection, and financial stability implications of the crypto-related activities. The FDIC indicates it will provide supervisory feedback after completing its review of the requested information.
Crypto Services Notification Request	2022-09-08	Dallas Regional Office	This document is a letter from the FDIC's Dallas Regional Office to a bank's Board of Directors regarding the bank's notification of intent to offer crypto-asset services through its digital and mobile banking platform in conjunction with a third party. The letter references FIL-16-2022 ("Notification of Engaging in Crypto-Related Activities") and requests extensive information to assess the safety and soundness, consumer protection, and financial stability implications of the proposed activities. The attached request list includes 26 items covering contracts, transaction flows, settlement processes, permissibility analysis, vendor management documentation, consumer disclosures, risk assessments, policies and procedures, and implementation plans. The FDIC indicates it will provide supervisory feedback after reviewing the requested information, which is due by October 14, 2022.
Cryptoasset Service Risk Concerns	2022-09-16	Chicago Regional Office	This letter from the FDIC to a bank's Board of Directors transmits an examination report that identifies increased risk due to the bank's implementation of a new cryptoasset service allowing customers to buy, sell, and hold Bitcoin through a third party. The letter includes a Matter Requiring Board Attention (MRBA) related to the cryptoasset service, noting that the bank's risk management program did not appropriately identify, quantify, and mitigate associated risks. The FDIC instructs the Board to ensure management conducts a robust assessment of the service to address potential risks, particularly consumer confusion, and to implement an effective risk management framework that includes a comprehensive risk assessment, thorough vendor due diligence, appropriate Board oversight, and a comprehensive compliance management system. The bank is directed to resolve these issues before expanding the cryptoasset service beyond its current customer base.
Crypto Vendor Due Diligence Review	2022-09-19	Kansas City Regional Office	This document is a letter from the FDIC's Assistant Regional Director to a bank's Board of Directors regarding a Report of Examination. The letter notes that on May 16, 2022, bank management notified the FDIC that it had started due diligence on a third-party vendor that would allow customers to buy/sell crypto assets. The FDIC requests notification when the bank completes due diligence and begins beta testing the product, as the FDIC intends to conduct a targeted review of the program to assess risk management practices, policies, procedures, and compliance with consumer protection and AML/CFT regulations prior to full implementation. The letter also references the Anti-Money Laundering Act of 2020, which amended the Bank Secrecy Act, and notes the FDIC's transition to using the term "AML/CFT program" rather than "BSA/AML compliance program."
FDIC Email Exchange on Crypto Activity Draft	2022-09-20	Atlanta Regional Office	This email thread discusses a bank's notification to the FDIC regarding crypto-related activities in response to FIL-16-2022. FDIC staff review the bank's submission and determine that the reported activities—ACH transactions flowing through deposit accounts and a loan secured by business assets (not by crypto)—fall outside the scope of the FIL. The emails document the internal FDIC review process, with staff preparing a draft letter to inform the bank that their crypto-related activity is outside the scope of the FIL, and the letter being routed through various FDIC personnel for review before sending it to the bank.
Bank's Crypto Partnership Withdrawal	2022-09-20	New York Regional Office	This document is a response from the FDIC's New York Regional Office to a bank's notification about withdrawing from a partnership with a company that would have provided customers the ability to purchase and sell Bitcoin. The bank cited crypto asset market volatility and evolving regulatory frameworks as reasons for withdrawal but indicated the partnership might be revisited. The FDIC acknowledges the notification and references FIL-16-2022, which requires FDIC-supervised institutions to notify the appropriate Regional Director about crypto-related activities. The FDIC requests that the bank notify the office prior to resuming the partnership or engaging in any other crypto asset-related services in the future, and provides instructions for submitting such notifications.
Trust Department Crypto Asset Update	2022-09-22	New York Regional Office	This memorandum documents the FDIC's receipt of correspondence from a bank's Senior Vice President regarding a new crypto-related holding in an existing client account within the trust department. The document details that a client requested the investment team to purchase shares of a specific crypto-related asset, with the net purchase amount specified. The memo notes that the client already had another crypto-related holding in their IRA. The document includes a table summarizing crypto-related assets held by the trust department upon client direction, with estimated market values as of a specific date, noting that most holdings have been negatively impacted by the current market environment.
FDIC Email Exchange on Crypto Activity Review	2022-09-22	Atlanta Regional Office	This document contains an email exchange regarding a legal referral for a bank's crypto-related activities. The discussion centers on a template letter being sent to a bank's board notifying them that their reported crypto-related activity falls outside the scope of FDIC guidance. The emails indicate that the bank's activities involve "crypto-related transactions" passing through deposit accounts. There is a clarification request to verify whether the activities involve cash generated from crypto activities being passed through the bank's deposit accounts, which would align with the region's past treatment of similar cases. The letter was reviewed and approved by Washington and Legal with no changes requested.
Bank's Bitcoin Service Evaluation Request	2022-09-26	Dallas Regional Office	This document is a letter from the FDIC's Regional Director to a bank's Board of Directors regarding the bank's notification about offering customers the ability to buy, sell, and hold Bitcoin through a third-party arrangement. The letter references FIL-16-2022, "Notification of Engaging in Crypto-Related Activities," which requires FDIC-supervised institutions to notify the FDIC about crypto-related activities. The FDIC requests extensive information from the bank by November 25, 2022, to assess safety and soundness, consumer protection, and financial stability implications of the proposed crypto activities. The letter includes a detailed 24-item request list covering documentation about contracts, transaction flows, settlement processes, vendor due diligence, consumer disclosures, fees, implementation plans, and other aspects of the bank's planned crypto-asset activities.
Bank's Crypto Service Plans	2022-09-26	Unknown	This document is an Interim Contact report detailing a bank's activities and changes. It notes that the bank has commenced fintech Banking-as-a-Service (BAAS) relationships and is performing third-party ACH sender services for an entity that has significantly impacted the balance sheet. The bank submitted notice of intent to engage in crypto-related services during the visit. The report mentions that management was informed that the question of whether deposits associated with a specific relationship should be considered brokered was under review. The document also records management's concerns about perceived FDIC resistance to new strategic pursuits, including BAAS relationships, with the FDIC noting these items involve new risks that need to be understood by the Board.
IRA Crypto Trade Inquiry	2022-10-05	Boston Area Office	This document contains an email exchange between a financial institution and the FDIC regarding a client's crypto-related holdings. The FDIC acknowledges receipt of correspondence about a client's holding of a crypto asset and requests documentation regarding the client's direction of the crypto asset, along with account name and account type information. The financial institution responds by providing information about an Individual Retirement Account and attaching transaction details. The exchange demonstrates the FDIC's ongoing monitoring of crypto-related activities and its information requests related to such activities.
Crypto Services Assessment	2022-10-12	Kansas City Regional Office	This document is a letter from the FDIC's Kansas City Regional Office to a bank's Board of Directors regarding the bank's notification of intent to offer crypto-asset services through its banking platform with a third-party partner. The letter acknowledges receipt of the bank's notification in response to FIL-16-2022 and requests extensive information to assess the safety, soundness, consumer protection, and financial stability implications of the proposed activities. The letter includes a detailed 29-item request list covering contracts, transaction flows, settlement processes, risk assessments, vendor due diligence, customer disclosures, fee structures, and other operational aspects of the proposed crypto-asset services. The FDIC indicates it will provide supervisory feedback after reviewing the requested information, which is due by November 30, 2022.
FDIC Email Exchange on Crypto Activity Letter	2022-10-25	New York Regional Office	This document contains email exchanges between FDIC personnel discussing a letter to be sent to a bank regarding its proposed third-party crypto-asset activity. The emails show consultation between regional and Washington office staff about the content and timing of the letter requesting information from the bank about its crypto-related activities. The discussion includes edits to the letter's language, particularly regarding timeframes for the bank to respond (with 60 days noted as the typical timeframe provided to banks), and modifications to avoid requesting that the bank submit another notification. The correspondence indicates the FDIC is requesting specific information from the bank about its proposed crypto-asset activities, with a deadline of December 30.
Crypto Lending Risks and Guidelines	2022-10-28	Chicago Regional Office	This letter from the FDIC to a bank's Board of Directors transmits a Report of Examination that discusses the bank's digital asset-related activities. While the bank's overall condition remains satisfactory, the FDIC notes concerns about the bank's digital asset-related lending, including elevated risk appetite, inadequate lending guidelines, and issues with Bitcoin collateral control and perfection. The letter references Financial Institution Letter 16-2022 and requests information to assess the safety and soundness implications of the bank's crypto-related activities. The FDIC recommends improvements to underwriting practices for digital asset loans, including better identification of repayment sources, documentation of collateral ownership, and independent collateral safekeeping arrangements.
Bank's Bitcoin Service Proposal Review	2022-11-01	New York Regional Office	This document is a letter from the FDIC's Regional Director to a bank's Board of Directors regarding the bank's notification about considering offering customers the ability to buy, sell, and hold Bitcoin through its branded online/mobile banking platform in conjunction with a third party. The letter acknowledges the bank's notification in response to FIL-16-2022 ("Notification of Engaging in Crypto-Related Activities") and notes that the bank is in exploratory stages and not currently engaged in crypto-related activities. The FDIC requests specific information by December 30, 2022, to assess safety and soundness, consumer protection, and financial stability implications of the proposed activities. The letter includes a detailed 25-item request list covering contracts, transaction flows, settlement processes, vendor management, customer disclosures, risk assessments, policies, and other documentation related to the proposed crypto-asset trading activity.
Review of Crypto Activity Plans	2022-11-04	San Francisco Regional Office	This letter from the FDIC to a bank's Board of Directors addresses the bank's proposed testing of digital asset accounts. The FDIC acknowledges the bank's three-year business plan submitted in response to FIL-16-2022 and subsequent notification of intent to test accounts with two digital asset infrastructure providers. The letter requests extensive additional documentation and information regarding the proposed test accounts for stablecoin and custody services, crypto lending, and market making activities. The FDIC's information requests cover due diligence on vendors, risk assessments, permissibility analyses, legal opinions on whether certain assets are securities, detailed descriptions of proposed activities, board minutes, draft contracts, compliance with SEC Staff Accounting Bulletin No. 121, and specific testing protocols. The FDIC reminds the bank not to proceed with planned activities until the FDIC completes its review and provides supervisory feedback.
Bank's Bitcoin Services Proposal Review	2022-11-07	Kansas City Regional Office	This document is a letter from the FDIC's Regional Director to a bank's Board of Directors regarding the bank's notification about its intent to offer crypto-related activities. The bank had informed the FDIC of plans to offer customers the ability to buy, sell, and hold bitcoin through its digital and mobile banking platform in partnership with a third party, as well as a debit card with bitcoin rewards. The letter also notes the bank had extended credit to a crypto-related entity. Following procedures outlined in FIL-16-2022, the FDIC is requesting detailed information to assess the safety and soundness, consumer protection, and financial stability implications of these activities. The letter includes two comprehensive request lists - one focused on crypto-asset collateralized commercial lending (requesting loan agreements, risk assessments, policies, and monitoring procedures) and another focused on the bank's partnerships with third parties for bitcoin services (requesting contracts, policies, transaction flows, fee structures, and customer disclosures).
Bank's Crypto Token and Sentry Node	2022-11-16	Dallas Regional Office	This letter from the FDIC to a bank's Board of Directors acknowledges receipt of the bank's June 9, 2022 response to the FDIC's April 25, 2022 information request. The FDIC notes that the bank was granted $500,000 in Hash tokens for use on the blockchain and requests additional details about this grant. The letter also addresses the bank's potential operation of a Sentry Node to facilitate payment system activities. The FDIC indicates that the bank should file an application under Part 362 of FDIC Rules and Regulations to obtain consent to hold tokens on its balance sheet and either provide documentation showing that operating a Sentry Node is permissible for national banks or seek FDIC consent under Part 362 for this activity. The letter references section 24 of the Federal Deposit Insurance Act, Part 362 of FDIC Rules and Regulations, and FIL-54-2014 regarding filing procedures.
Bitcoin Service Risk Management Guidance	2022-11-17	Chicago Regional Office	This letter from the FDIC to a bank's Board of Directors provides supervisory feedback on the bank's proposed Bitcoin service through its online banking platform. The FDIC reviewed the bank's August 10, 2022 letter and related documents in response to the FDIC Crypto Asset Facilitation Request List. The letter identifies potential risks associated with crypto-related activities, including compliance, legal, operational, third-party, and strategic risks, as well as customer confusion concerns. The FDIC notes that various aspects of the bank's risk and compliance management framework for this service are still in development, including due diligence, contract review, legal analysis, policies, and customer-facing materials. The letter provides recommendations for the bank to consider, including clear disclosures to customers, developing an effective compliance management system, ensuring staff can respond to customer inquiries, and establishing monitoring criteria. The FDIC requests notification of material developments and submission of fully developed risk management documentation before implementing the proposed activity, referencing FIL-16-2022 and FIL-35-2022.
Bank's Crypto Service Delayed Post-FTX	2022-11-17	Kansas City Regional Office	This memorandum documents a meeting between FDIC representatives and bank management regarding the bank's proposed crypto facilitation service planned for early 2023. The bank reported no progress since their September meeting and expressed concerns about proceeding with the service following the FTX bankruptcy news. Management indicated the service was intended to help the bank remain competitive rather than generate significant revenue, but they were considering pausing or aborting the project altogether. The bank's COO noted that their application programming interface with a third party was stalled. The FDIC representative explained that while the agency takes no position on the topic, they could serve as a resource to help identify risks, establish controls, and ensure clear consumer disclosures. The FDIC mentioned they would send a request list prior to implementation if the bank decided to proceed, but would hold off on sending this list given the bank's plans to pause the project.
Crypto Deposits Discussion	2022-11-17	Chicago Regional Office	This document contains email correspondence between an FDIC case manager and a bank representative regarding digital asset-related activities. The bank representative provides information about crypto-related deposits, specifically $17 million from a crypto-related hedge fund that came through another entity. The correspondence appears to be follow-up information from a call with the bank's president, where the FDIC requested details about trends in the bank's digital asset-related deposits and loans. The document shows the FDIC's information-gathering process regarding a bank's crypto-related activities.
Follow Up Inquiries on DLT Use and Vendor	2022-11-21	San Francisco Regional Office	This document is a letter from the FDIC to a bank requesting additional information about the bank's engagement in blockchain-based digital records and its relationship with a technology vendor, following the bank's notification in response to FIL-16-2022 (Notification of Engaging in Crypto-Related Activities). The letter includes an extensive attachment with 18 detailed information requests about the bank's crypto-related activities, including questions about transactions recorded on Distributed Ledger Technology (DLT)/blockchain, the use of native tokens, node structure, smart contracts, recordkeeping processes, projected transaction volumes, board approval documentation, website details, risk assessments, contracts with vendors, and Non-Fungible Tokens (NFTs). The FDIC indicates it needs this information to assess the safety and soundness, consumer protection, and financial stability implications of the bank's activities.
Permissibility of Holding Certain Tokens an Operating Sentry Node	2022-11-21	New York Regional Office	This letter from the FDIC to a bank acknowledges receipt of the bank's June 20, 2022 response to the FDIC's April 25, 2022 information request, but notes that acknowledgment does not constitute non-objection. The FDIC identifies that the bank holds tokens used for transactions on a blockchain and may operate a Sentry Node to facilitate certain activities. The FDIC determines that the bank should file an application under Part 362 of FDIC Rules and Regulations requesting consent to hold these tokens on its balance sheet and obtain prior consent before acquiring additional tokens. Regarding the Sentry Node operation, the bank must either provide documentation per FDIC FIL-54-2014 or seek prior consent under Part 362. The letter references Section 24 of the Federal Deposit Insurance Act, Part 362 of FDIC Rules and Regulations, and Section 303.121(b) regarding required filing contents.
Bank Pauses Crypto Services	2022-11-23	Dallas Regional Office	This document is a letter from the FDIC Regional Director to a bank's Board of Directors regarding the bank's notification about offering crypto-asset services through its digital and mobile banking platform. The letter outlines the sequence of events - the bank's initial notification on April 19, 2022; the FDIC's request on May 4, 2022, that the bank not proceed while the FDIC assessed the activity; a subsequent FDIC information request on September 8, 2022; and the bank's October 21, 2022 communication that it had paused the Bitcoin services activity with no definitive timeframe for revisiting it. The FDIC acknowledges this pause, notes that its previous letter has been superseded, and requests notification of any future changes to this or other crypto-related activities. The letter references FIL-16-2022, "Notification of Engaging in Crypto-Related Activities."
FDIC Email Exchange on Crypto Asset Compliance	2022-11-28	Boston Area Office	This email thread discusses crypto-related holdings at a bank, focusing on assets held in trust and custody accounts. An FDIC examiner reports that a bank has client-directed crypto holdings across its trust department and custody division, including approximately 124 domestic/international clients with various crypto assets. The discussion includes questions about whether banks should report crypto-related trust assets to the FDIC under FIL-16-2022, how these assets are acquired and custodied, and clarification about the bank's structure where some crypto custody activities occur through a registered broker-dealer subsidiary. The correspondence indicates the FDIC is gathering information about the nature of these holdings, whether they were client-directed or recommended by investment managers, and how banks are handling crypto assets in trust and custody relationships.
Bank Halts Third-Party Bitcoin Service Plans	2022-11-30	Dallas Regional Office	This letter from the FDIC acknowledges a bank's notification regarding its intent to offer bitcoin services through a third-party arrangement with an unnamed entity, submitted pursuant to FIL-16-2022 "Notification of Engaging in Crypto-Related Activities." The FDIC notes that the bank subsequently informed them that it does not intend to offer bitcoin services or perform testing at this time. The FDIC requests that the bank notify the office if the status of these activities or any other proposed crypto-related activity changes in the future. The letter references confidentiality requirements under part 309 of the FDIC Rules and Regulations and provides contact information for questions related to safety and soundness or CRA/consumer compliance.
Bank Abandons Crypto Activities	2022-12-01	San Francisco Regional Office	This email thread documents interactions between FDIC personnel regarding a bank's potential crypto asset relationship. The correspondence reveals that the FDIC was following up with banks engaged in or proposing digital asset activities to remind them of an outstanding FIL (Financial Institution Letter) and request written responses about such activities. In a follow-up communication, an FDIC representative reports having spoken with the bank's CEO, who indicated that the bank decided to abandon its crypto-related plans due to market volatility, regulatory risk, and other concerns. The CEO acknowledged awareness of the FIL and committed to informing the FDIC if they reconsider crypto activities in the future.
Follow-Up on Bitcoin Facilitation	2022-12-01	New York Regional Office	This letter from the FDIC's New York Regional Office follows up on a bank's response to an Information Request regarding Third-Party Bitcoin Facilitation Activity. The FDIC indicates that the bank's October 31, 2022 response was missing or incomplete information on several items. The letter includes an appendix detailing specific follow-up items needed, including the executed Financial Institution Terms & Conditions, contract analysis, settlement process details, permissibility analysis, SEC SAB 121 correspondence, cost-benefit analysis, vendor management documentation, implementation plan, consumer disclosures, marketing materials/screenshots, strategic plan, board minutes showing approval of Bitcoin facilitation, training materials, crypto-related policies and procedures, and internal control responsibilities. The FDIC requests these items within 15 days and indicates a meeting will be scheduled after receipt to discuss the material.
Crypto Compliance Document Request	2022-12-01	Chicago Regional Office	This document contains a follow-up request from the FDIC to a bank regarding crypto-asset activities. The FDIC is requesting additional information after receiving a live demo of the bank's platform. The request includes 11 specific items the bank needs to provide by December 14, including consumer compliance risk assessment, legal analysis of permissibility under Part 362 of FDIC Rules and Regulations, documentation regarding SAB 121 confirmation with external auditors, due diligence documentation, signed agreements, resolution of attorney concerns, vendor management policies, information about digital team members and internal controls, transaction flow data, and plans for ongoing monitoring and audit of crypto-related products and services. The FDIC indicates they will evaluate these documents before determining next steps.
FDIC Requests Crypto Activity Documentation	2022-12-13	Chicago Regional Office	This letter from the FDIC acknowledges a bank's notification regarding its intent to partner with another entity to offer blockchain technology services. The notification was provided pursuant to FIL-16-2022, which requires FDIC-supervised institutions to notify the FDIC about crypto-related activities. While the bank provided a summary of proposed activities, implementation timeline, risk management program, and vendor due diligence process, the FDIC states it needs additional documentation to evaluate safety and soundness, consumer protection, and financial stability considerations. The letter includes a request for additional information with a response deadline, referencing the enclosed documentation request that the bank must address.
Bank Crypto Kiosk Compliance Report	2022-12-13	Unknown	This document is a transmittal letter from the FDIC's Division of Depositor and Consumer Protection to a bank's Board of Directors regarding a Consumer Compliance Report of Examination. The letter specifically requests a written response from the bank concerning a recommendation about ensuring appropriate controls are in place to minimize potential customer confusion regarding the bank's arrangement with an entity to place crypto kiosks inside bank branches. The bank is required to provide details and supporting documentation, including disclosure and signage language placed on and around the kiosk locations, as well as in brochures and other print materials available to consumers. The letter indicates that the Board must review the Report at an official meeting and document this review in the meeting minutes.
FDIC Email Exchange on Crypto Draft Letter	2022-12-15	Boston Area Office	This document contains an email exchange between an FDIC case manager and a recipient regarding a draft letter related to an unspecified matter. The FDIC case manager shares a draft letter that they plan to issue shortly, noting that previous correspondence between the bank and the FDIC on the matter is available in RADD. The recipient responds that the draft letter "looks good." The document does not specify the content of the draft letter or whether it relates to crypto-related activities, nor does it contain details about specific bank interactions, concerns, instructions, or regulatory references.
Notify Before Crypto Activities	2022-12-19	Boston Area Office	This letter from the FDIC Regional Director to a bank's Board of Directors addresses the bank's consideration of offering bitcoin buy/sell services to customers through third parties. The letter references Financial Institution Letter (FIL)-16-2022, which requires FDIC-supervised institutions to notify the FDIC prior to engaging in crypto-related activities. During a Safety and Soundness examination, the bank discussed its interest in crypto services but was unable to provide requested documentation as it remains in exploratory stages without a determined timeline. The FDIC requests the bank to keep them updated on any progress, determinations, or proposed timelines related to crypto activities, and reminds the bank that the FDIC will review submitted information, request additional information as needed, and provide supervisory feedback.
Crypto Conflict of Interest Email Exchange	2022-12-20	San Francisco Regional Office	This document contains an email exchange regarding a potential relationship between a crypto entity and an insured depository institution (IDI). The initial email requests information about a specific entity that may have a fintech relationship or deposits with a bank, noting concern about indirect impacts on IDIs that have relationships with this entity. The response indicates that the FDIC has spent considerable time on the matter, mentions that one individual has a conflict of interest with crypto matters, and notes that a different Case Manager is now handling the specifics of the situation. The email also references a memo that may have been updated regarding the entity in question.
FDIC Letter on Bank's Crypto Activities Plan	2022-12-23	Chicago Regional Office	This letter from the FDIC Regional Director to a bank's Board of Directors responds to the bank's notification about its intent to work with a third party to develop an API for crypto asset transactions through the bank's digital banking platform. The letter acknowledges the bank's notification under FIL-16-2022 and a subsequent discussion where the bank indicated it created test accounts for API development but does not intend to offer crypto services to customers. The FDIC requests detailed information about the planned activities, including risk assessments, board documentation, third-party relationships, contracts, policies, technical details about the API development, testing procedures, and customer disclosures. The letter includes an 18-item request list covering various aspects of the crypto-asset activity, with a deadline for the bank to provide this information for the FDIC's safety and soundness assessment.
Bank's Crypto Legal Analysis Request	2022-12-29	San Francisco Regional Office	This letter from the FDIC Regional Director to a bank president follows up on the bank's response to an earlier information request regarding crypto-related activities. The FDIC notes that the bank only partially addressed a previous request for an independent legal analysis of the permissibility of acquiring and holding crypto-assets and NFTs under part 362 of FDIC Regulations and other relevant laws. The letter reiterates the request for legal analysis and supporting documentation, referencing FIL-54-2014 regarding filing and documentation procedures for state banks engaging in activities permissible for national banks. The FDIC requests the bank provide this analysis within 30 days.
Bank Halts Bitcoin Service Exploration	2023-01-05	Boston Area Office	This letter from the FDIC acknowledges a bank's notification about its intent to explore offering bitcoin services to customers through third parties, which was submitted pursuant to FIL-16-2022 requiring FDIC-supervised institutions to notify the FDIC about crypto-related activities. The FDIC had requested additional information about the proposed activity, but the bank subsequently informed the FDIC that it had suspended its exploratory phase for new bitcoin services in conjunction with specified partners and technology providers. The FDIC acknowledges this suspension and requests that the bank notify the FDIC if the status of this activity or other crypto-related activities changes in the future.
Concerns Over Bank's Crypto Proposal	2023-01-05	New York Regional Office	This letter from the FDIC Regional Director to a bank president addresses the bank's proposed crypto-related product involving a decentralized public blockchain. The FDIC expresses several safety and soundness concerns about the product, including the use of a decentralized public blockchain without customary governance mechanisms; the bank's reliance on third-party nodes without contractual relationships; challenges in risk quantification and monitoring; information security issues related to publishing customer transactions on a public blockchain; and the bank's plan to hold crypto-assets as a node operator. The letter references Appendices A and B to Part 364 and Part 362 of FDIC Rules and Regulations, and concludes that the FDIC is unable to determine that the bank can conduct the proposed product or pilot in a safe and sound manner.
Bank Terminates Crypto Services Plan	2023-01-06	Dallas Regional Office	This letter from the FDIC's Dallas Regional Office acknowledges a bank's notification that it has terminated an agreement with a partner related to offering customers the ability to buy, sell, and hold Bitcoin and Ethereum through the bank's digital and mobile banking platforms. The document outlines the timeline of interactions between the FDIC and the bank, including the bank's initial notification in February 2022 referencing FIL-16-2022, the FDIC's April 2022 request that the bank not proceed with implementation, an August 2022 FDIC request for information to assess safety and soundness implications, and discussions during a December 2022 Safety and Soundness examination. The FDIC confirms that its previous letter has been superseded due to the bank's withdrawal from the crypto project and requests notification if the status of this or other crypto-related activities changes in the future.
Bank Halts Bitcoin Services	2023-01-09	Dallas Regional Office	This letter from the FDIC's Dallas Regional Office acknowledges a bank's decision to no longer pursue previously proposed crypto-related activities with a third party. The document outlines the timeline of interactions between the bank and the FDIC, including the bank's initial notification on February 25, 2022, about its intent to offer customers the ability to buy, sell, and hold Bitcoin through its digital and mobile banking platform. The FDIC had requested the bank pause all crypto-related activity on March 11, 2022, and later requested additional information on September 26, 2022, consistent with FIL-16-2002, "Notification of Engaging in Crypto-Related Activities." The FDIC confirms that its previous letters have been superseded due to the bank's December 12, 2022, communication indicating it would not pursue the crypto activity, but requests notification if the status changes in the future.
Crypto Kiosk Compliance Measures	2023-01-10	Unknown	This letter responds to an FDIC Compliance Report of Examination dated June 21, 2022, addressing concerns about potential customer confusion regarding bitcoin kiosks placed in bank branches through an arrangement with a third party. The bank describes implementing controls including adding disclaimers on brochures and machines stating that the crypto products are "Not FDIC Insured," "Not a deposit or bank product," "Not insured by any Federal Government Agency," "Not guaranteed by the bank," and "May go down in value." The bank also requested the third party to add these disclaimers to QR code information, brochures, and their website location pages for the bank's branches to clearly distinguish the crypto offerings from FDIC-insured bank products.
Bank Halts Blockchain Payment Program	2023-01-10	New York Regional Office	This document is a letter from the FDIC to a bank's Board of Directors acknowledging the bank's notification about its engagement in crypto-related activities with a company that offered a payment program using blockchain technology. The letter references the bank's compliance with FIL-16-2022, which requires FDIC-supervised institutions to notify the FDIC about crypto-related activities. The FDIC acknowledges that the bank is no longer engaging in the previously notified crypto activity, as communicated in an email from a Senior Vice President. The FDIC requests that the bank provide notification if it resumes this activity or engages in other crypto-related activities in the future, and provides instructions for submitting such notifications.
Bank Suspends Bitcoin Activities	2023-01-13	New York Regional Office	This letter from the FDIC's New York Regional Office acknowledges a bank's notification about its intent to offer customers the ability to buy, sell, and hold crypto-assets through its digital and mobile banking platforms. The document outlines a sequence of interactions between the FDIC and the bank, including the bank's initial notification pursuant to FIL-16-2022, the FDIC's request for the bank to refrain from expanding the service, subsequent information requests from the FDIC to assess safety and soundness implications, and ultimately the bank's decision to indefinitely suspend its plan to engage in third-party Bitcoin facilitation activity. The FDIC acknowledges this suspension, notes that previous information request letters have been superseded, and requests notification if the status of this or other crypto-related activities changes in the future.
Bank Ceases Crypto Activities	2023-01-17	New York Regional Office	This document is a letter from the FDIC acknowledging a bank's notification about its engagement in crypto-related activities with a third party that offered digital assets, where the third party maintained a deposit account at the bank to hold U.S. dollars exchanged for digital assets. The letter references FIL-16-2022, which requested FDIC-supervised institutions to notify the appropriate FDIC Regional Director about crypto-related activities. The FDIC acknowledges the bank's subsequent update that it is no longer engaging in the previously notified crypto-related activity and requests that the bank notify the FDIC and the state regulator if the status of this activity or other crypto-related activities changes in the future.
Bank Halts Crypto Activities	2023-01-17	New York Regional Office	This letter from the FDIC Regional Director acknowledges that a bank had previously engaged in crypto-related activities with a company that offered digital assets using blockchain technology, where the company maintained a deposit account at the bank to hold U.S. dollars exchanged for digital assets. During an FDIC examination, the FDIC requested information to assess the safety and soundness implications of this activity. The bank subsequently informed the FDIC that it was no longer engaging in this digital-based activity, as the company had ceased offering digital assets. The FDIC acknowledges this status change and requests notification if the bank's involvement in this or other crypto-related activities changes in the future, referencing FIL-16-2022 regarding notification requirements for crypto-related activities.
FDIC Email Exchange on Crypto Request Approval	2023-01-24	Boston Area Office	This document contains an email exchange regarding a draft letter and request list for a bank concerning its planned crypto facilitation activity through a partnership with another entity. The FDIC staff discusses using a template request list for the bank's digital asset activities, noting that Washington review is not required when using the standard template without deviations. The exchange shows the internal review process for the letter, which requires signature from a senior FDIC official before being sent to the bank.
Bank's Crypto Services Notification	2023-01-24	New York Regional Office	This document is a letter from the FDIC's Regional Director to a bank's Board of Directors regarding the bank's notification of intent to offer cryptocurrency services through its mobile banking platform in conjunction with a third party. The letter references FIL-16-2022, "Notification of Engaging in Crypto-Related Activities," which requires FDIC-supervised institutions to notify the FDIC about crypto-related activities. The FDIC requests extensive information from the bank by a specific deadline to assess safety and soundness, consumer protection, and financial stability implications. The letter includes a detailed 26-item request list covering contracts, transaction flows, settlement processes, permissibility analysis, vendor due diligence, customer disclosures, risk assessments, and implementation plans related to the bank's proposed crypto-asset activities involving customer purchase and sale of cryptocurrencies through a third party.
FDIC-Bank Email Exchange Discussion Crypto Activity	2023-01-27	Kansas City Regional Office	This document is an email from an FDIC Case Manager requesting additional information from a bank regarding its crypto-related activities. The FDIC asks for updates on the status of the bank's crypto testing phases, including Employee Testing, Beta Testing, and Soft Launch. The regulator requests information about customer disclosures for cryptocurrency transactions, screenshots of the bank's mobile application related to crypto services, and details about any fees charged for crypto transactions. The FDIC also inquires about recordkeeping processes for customer accounts eligible for FDIC deposit insurance, including documentation of deposit insurance applicability, fund flow procedures, and agreements between parties. Additionally, the email seeks updates on other crypto products/services that were previously reported as not yet built, and information about a proposed change to an existing customer account that would allow account holders to purchase crypto assets.
Bank Suspends Crypto Activities	2023-02-07	Kansas City Regional Office	This memorandum documents interactions between an FDIC Case Manager and a prospective bank president regarding the bank's interest in offering crypto assets transaction services in partnership with third parties. The document notes that throughout the fourth quarter of 2022, there were several conversations and information requests related to this endeavor. Following a discussion with FDIC representatives about concerns regarding the readiness of the proposed interface provider, the prospective president and the bank's Board decided to suspend their pursuit of crypto asset activity.
Bank Halts Crypto Services Plan	2023-02-13	New York Regional Office	This document is a letter from the FDIC's Regional Director acknowledging a bank's notification of intent to offer crypto-asset services through its mobile banking platform. The bank had notified the FDIC pursuant to FIL-16-2022, "Notification of Engaging in Crypto-Related Activities," which requires FDIC-supervised institutions to notify their Regional Director about crypto-related activities. The FDIC had requested additional information to assess safety and soundness implications, but the bank subsequently informed the FDIC that it had put its digital assets project on hold. The FDIC acknowledges this change in status, notes that the bank no longer needs to respond to the previous information request, and asks to be notified of any future changes regarding this or other crypto-related activities.
FDIC Email Exchange on Paused Crypto Project	2023-02-13	Boston Area Office	This document contains email correspondence regarding a letter to a bank that has put its cryptocurrency plans on hold. The bank notified the FDIC that it has suspended its digital asset activity plans and requested to be relieved from responding to an FDIC information request. FDIC staff drafted a letter to confirm this change, modeling it after a similar letter sent to another bank. The email thread shows FDIC staff reviewing and editing the letter for consistency with other communications before finalizing it for delivery to the bank.
Bank's Crypto Risk Management Deficiencies	2023-02-15	Chicago Regional Office	This document is a letter from the FDIC to a bank's Board of Directors regarding deficiencies in the bank's management of crypto-asset services provided through a third-party vendor. The FDIC identifies several concerns including inadequate risk assessment, insufficient vendor due diligence, weak compliance management systems, and poor Board oversight related to the bank's crypto-asset service. The letter details specific shortcomings in the bank's handling of transactional, strategic, and legal risks, as well as concerns about customer confusion regarding FDIC insurance coverage for crypto assets. The FDIC notes that crypto-related activities pose safety and soundness risks and consumer protection risks, and outlines the bank's contractual responsibilities including transaction transmission, customer identification, transaction monitoring, and providing consumer disclosures. The letter requests a response from the bank by March 31, 2023.
Crypto Strategy Meeting with Bank	2023-02-15	Kansas City Regional Office	This memorandum summarizes a meeting between FDIC representatives and bank leadership. The bank's CEO outlined two strategic directions - continuing as a community bank with improved technology and enhancing their banking model through partnerships with large third parties. The discussion included the bank's involvement with crypto assets, specifically accepting certain cryptocurrencies as collateral, with management restricting acceptance to mature cryptocurrencies initially but open to expanding in the future. The FDIC Regional Director stated they are not categorically opposed to banks engaging in crypto activities but need to ensure such activities align with risk management expectations and consumer compliance requirements. The FDIC indicated they would pose additional questions regarding the bank's planned crypto-related program.
Crypto Assets Visitation Scheduled	2023-02-27	Dallas Regional Office	This letter acknowledges receipt of documents submitted by a bank on January 25, 2023, in response to the FDIC's December 12, 2022 email regarding crypto assets-related activity. The FDIC indicates it is continuing to review the bank's crypto-related activities and has questions remaining. Referencing FIL-16-2022 "Notification of Engaging in Crypto-Related Activities," the FDIC announces plans to schedule a Visitation at the bank starting April 10, 2023, with participation from another regulatory body (redacted), to assess the safety and soundness, consumer protection, and financial stability implications of the proposed crypto activity. The letter provides contact information for questions and instructions for submitting written correspondence.
FDIC Letter on Bank's Crypto Divestment	2023-03-01	San Francisco Regional Office	This letter from the FDIC's San Francisco Regional Office responds to a bank's plan to divest crypto-assets. The FDIC clarifies that the proposed transaction does not require FDIC approval or a formal filing. The letter instructs the bank to ensure appropriate valuation and valuation methodology of the crypto-assets, maintain adequate documentation supporting the valuation, accounting entries, and compliance with Sections 23A and 23B of the Federal Reserve Act. The FDIC requests written confirmation if the bank proceeds with the transaction, including the date of completion, and notes that supporting documentation will be reviewed in future examinations.
Feedback on Bank's Crypto Plans	2023-03-03	Chicago Regional Office	This letter from the FDIC to a bank's Board of Directors provides supervisory feedback on the bank's proposed crypto-asset activity involving a third-party API development that would allow customers to buy, sell, and hold crypto assets through the bank's digital banking platform. The FDIC notes that the bank has completed minimal risk assessment and due diligence activities on the third-party provider. The letter outlines specific supervisory feedback, including the need for comprehensive due diligence, appropriate risk frameworks, and information security considerations before granting core banking system access to a third party. The FDIC references FIL-16-2022 "Notification of Engaging in Crypto-Related Activities" and requests that the bank provide a response within 45 days, notify the FDIC of any material developments related to the proposed testing, and inform the FDIC prior to implementing any crypto-asset services for customers.
Bank's Crypto Activity Update	2023-03-13	Atlanta Regional Office	This document is a letter from the FDIC's Atlanta Regional Office to a bank's Board of Directors regarding the bank's notification about crypto-related activities. The letter acknowledges the bank's August 24, 2022 notification about plans to participate in testing of a payment network that allows FDIC-insured banks to offer instant payments and other payment solutions. The notification was provided pursuant to FIL-16-2022, which requires FDIC-supervised institutions to notify the FDIC about crypto-related activities. The letter notes that while the bank participated in testing on October 1, 2022, the bank's president later informed the FDIC that the bank has no plans to utilize the network. The FDIC requests notification of any future changes in status of this activity or other crypto-related activities, including any proposed material changes to the internal payment service or expansion to include clients, transactions, or activities outside the bank.
FDIC-Bank Email Exchange Ends in Crypto Activities Halt	2023-03-15	Chicago Regional Office	This email thread documents discussions between FDIC personnel regarding a bank's crypto-related activities. The bank initially expressed interest in pursuing crypto activities, which was discovered during a joint examination in April 2022. By March 2023, the bank's president informed the FDIC that they were no longer pursuing any crypto-related activities, citing recent events related to FTX as the reason for their decision. The correspondence shows the FDIC's internal monitoring process for banks interested in crypto activities, including requests for updates during interim contacts and discussions about whether the bank had submitted formal notifications about their crypto plans. The bank had previously indicated they were not close to implementing crypto activities and were waiting for regulatory guidance on permissibility.
Notice of Crypto Activities to FDIC	2023-03-27	Unknown	This document appears to be an email with the subject line "Notice of Engaging in Crypto-Related Activities.pdf," sent to an FDIC employee. The email appears to be transmitting a document related to a notice about engaging in crypto-related activities, though the content of the attached PDF is not included in the provided text.
Bank Ceases Bitcoin Service Plans	2023-04-11	Chicago Regional Office	This document is a letter from the FDIC's Chicago Regional Office to a bank's Board of Directors regarding the bank's notification to offer customers the ability to buy, sell, and hold Bitcoin through digital and mobile banking platforms in partnership with a third party. The letter outlines the sequence of events following the bank's May 2022 notification, including the FDIC's request for delay of crypto-asset services expansion, information requests to assess safety and soundness implications, a platform demonstration, and additional information gathering during a Safety and Soundness Visitation. The FDIC acknowledges the bank's February 2023 decision to cease providing bitcoin services to customers and notes that the bank will allow time for employees to unwind their positions before terminating access to the third-party platform. The FDIC requests notification if the status of this or other crypto-related activity changes in the future.
Bank's Crypto Activities and FBO Compliance	2023-04-18	Kansas City Regional Office	This memorandum documents interactions between the FDIC and a bank regarding crypto-related activities, specifically the bank's establishment of a For Benefit Of (FBO) account for a crypto-related entity. The document outlines a timeline of events from April 2022 to April 2023, including the bank's notification to the FDIC about offering services to a crypto entity, the FDIC's determination that the activity falls under FIL-16-2022 requiring formal notification, and a subsequent meeting where bank management provided details about the FBO account. During the April 11, 2023 meeting, bank management disclosed that the account had been opened in April 2022 but operated with commingled funds rather than as a true FBO account, with plans to transition to a proper FBO structure. The bank also indicated interest in onboarding additional digital asset-related entities, and the FDIC noted that supervisory feedback would be forthcoming in a letter.
Bank's Crypto Verification Service Evaluation	2023-04-19	Chicago Regional Office	This document is a letter from the FDIC's Chicago Regional Office acknowledging a bank's notification of its intent to offer a third-party authorization verification service for customer transactions in crypto-assets, as required by FIL-16-2022. The FDIC indicates that while the bank provided a summary of proposed activities, additional documentation is needed to evaluate safety and soundness, consumer protection, and financial stability considerations. The letter includes an extensive attachment requesting detailed information across multiple categories - general information about the proposed activities (including transaction verification, node functions, and multi-signature processes), technical details (transaction flow diagrams, custody solutions, logical controls), operational aspects (implementation timelines, risk assessments, third-party due diligence), and consumer protection information (customer agreements, fee structures, marketing materials). The bank is asked to respond by May 31, 2023.
Bank's Crypto-Asset Service Plans	2023-04-24	Chicago Regional Office	This letter from the FDIC to a bank's Board of Directors addresses the bank's notification of intent to offer crypto-asset services to customers. The document outlines a timeline of interactions between the FDIC and the bank, including the bank's initial notification on June 30, 2022, in response to FIL-16-2022, a subsequent FDIC letter requesting delay of crypto-asset service expansion and information by October 18, 2022, and the bank's request for more time. The FDIC notes that as of March 28, 2023, the bank reported not expecting to launch crypto-related activities before Q4 2023, and that the FDIC has not received any of the previously requested information. The letter reminds the bank to keep regulators updated on its crypto-asset plans and reiterates that the bank should not proceed with planned activities until the FDIC completes its review.
FDIC Email Exchange on Crypto Activity Monitoring	2023-04-24	San Francisco Regional Office	This document contains email correspondence regarding the FDIC's supervision of a bank's relationship with a crypto firm. The emails discuss the bank's involvement with a crypto customer that serves as a custodian of crypto customers, with FDIC examiners tracking the deposit accounts and potential cryptocurrency activity. The correspondence indicates that while the crypto firm had accounts at the bank, these accounts primarily reflected capital raises rather than active cryptocurrency transactions at the time of examination. The emails show FDIC staff collaborating on examination findings, requesting clarification about the nature of the crypto-related activities, and planning follow-up during future examinations to monitor the relationship. The document includes discussion of deposit account balances and mentions that bank management provided information indicating the accounts are or will be utilized for cryptocurrency activity.
Crypto Activity Inquiry and Guidelines	2023-04-26	San Francisco Regional Office	This document is an email from an FDIC Case Manager requesting additional information from a bank regarding its notification to the FDIC about potential crypto activity. The email contains specific questions about the bank's planned crypto-related activities, including requests to identify the customer or business involved, explain the services the bank plans to offer, clarify the nature of the accounts, identify the source of funds, provide supporting documents for the bank's plan to move deposits off its balance sheet, and address implications for the bank's liquidity and capital management. The Case Manager notes that this is a process and additional questions may be necessary.
Bank Cancels Bitcoin Service Plan	2023-04-26	Dallas Regional Office	This letter from the FDIC's Dallas Regional Office acknowledges a bank's notification of intent to offer Bitcoin services through a third-party arrangement with an unnamed provider. The notification was provided pursuant to FIL-16-2022, "Notification of Engaging in Crypto-Related Activities." Following the notification, the FDIC requested information to assess safety and soundness implications and asked the bank to refrain from providing the service until review completion. The FDIC sent follow-up questions and planned a Visitation to review the proposed activities. However, the bank subsequently informed the FDIC that its Board decided to cancel the arrangement and cease pursuing crypto-related activities. The FDIC acknowledges this decision, cancels the planned Visitation, and notes that its previous letter has been superseded, while requesting notification if the status of these or other crypto-related activities changes.
Crypto Activities Examination Report	2023-05-05	San Francisco Regional Office	This document is a transmittal letter for a Joint FDIC and state regulatory Report of Examination, which includes findings on safety and soundness, AML/CFT, IT, and the Bank's Digital Banking Division. The letter notes that regulatory comments regarding the Digital Banking Division will be provided separately. It acknowledges that the bank's future digital bank activities remain under development and recognizes management's commitment to pause all digital bank activities until receiving regulatory feedback. The letter requests that board members review the Report, sign an acknowledgment page, record the review in Board minutes, and respond to the findings within 45 days. It also includes standard confidentiality notices regarding the Report.
Bank's Crypto Plans Suspended	2023-05-18	New York Regional Office	This letter summarizes findings from a joint FDIC and state regulator Crypto-Assets Visitation conducted to review a bank's planned crypto-asset initiatives. The bank had notified regulators of its intent to offer crypto-asset secured lending, custodial services, and a buy/sell/trade program, but later postponed the lending pilot and focused only on a crypto-asset custody and buy/sell program. The visitation found that risk management processes and controls for the program were not fully developed, implemented, or tested, with incomplete documentation and undeveloped consumer disclosures. Given these deficiencies and existing risk management issues identified in previous examinations, the FDIC could not conclude the bank could conduct the program safely and compliantly. The bank subsequently suspended the initiative but later notified regulators of its intent to provide an account to hold deposit reserves for a stablecoin issuer, prompting the FDIC to instruct the bank not to proceed with any crypto-asset activity until regulators determine it can be implemented safely.
Bank Withdraws Crypto Plans	2023-05-19	Dallas Regional Office	This document is a letter from the FDIC's Dallas Regional Office to a bank's Board of Directors regarding the withdrawal of a crypto-asset notification. The letter acknowledges that the bank had previously notified the FDIC about plans to engage in crypto-asset related activities on November 16, 2022, which led to conversations between FDIC staff and bank management and requests for additional information. The letter confirms that the bank has terminated all future plans to allow FinTech customers to have crypto-related services, as indicated in the bank's March 21, 2023 letter, and that the FDIC is closing its files regarding the bank's crypto-related activities. The letter advises that if the bank decides to pursue crypto-related services in the future, it should provide prior notification to the FDIC, referencing Financial Institution Letter 16-2022 for guidance.
Bank Abandons Crypto Activity Plans	2023-05-19	New York Regional Office	This document is a letter from the FDIC's Regional Director to a bank's Board of Directors regarding the bank's notification about crypto-related activities. The bank had notified the FDIC on April 20, 2022, about its intent to join a technology provider that would enable customers to buy, sell, and hold bitcoin and Ether, in accordance with FIL-16-2022 which requires FDIC-supervised institutions to notify the FDIC about crypto-related activities. The FDIC subsequently requested information to assess the safety and soundness implications of these activities. The letter acknowledges that the bank later informed the FDIC it had not implemented and was not pursuing the proposed crypto-related activities, and requests notification if the status changes in the future.
Bank's Crypto Activities Evaluation	2023-05-25	Chicago Regional Office	This letter from the FDIC to a bank's Board of Directors acknowledges receipt of the bank's notification to partner with XXXXX to offer XXXXX and XXXXX to customers, submitted pursuant to FIL-16-2022 "Notification of Engaging in Crypto-Related Activities." The FDIC notes that while the bank has decided to no longer proceed with XXXXX, they will continue reviewing the bank's implementation of XXXXX. The letter requests additional information needed to evaluate the proposed activities, noting that some previously requested items were not provided in the bank's recent submission. The FDIC reiterates its previous instruction that the bank should not proceed with the planned activity until the FDIC completes its review and provides supervisory feedback, and requests notification of any material changes to the planned service.
ARDs to Monitor Crypto Activities	2023-06-06	San Francisco Regional Office	This email instructs Assistant Regional Directors (ARDs) to have case managers check in with banks that have connections with a redacted entity to see if they have observed any unusual activities, such as deposit activity. The email notes that if the bank is supervised by another agency, the case manager should plan to touch base as part of routine communications with the other agency contact. The email also mentions that a redacted individual is traveling to a redacted meeting and will have limited availability to assist with these calls over the next couple of days.
Bank's Crypto-Asset Activities Delayed	2023-06-14	Kansas City Regional Office	This document is a letter from the FDIC to a bank's Board of Directors regarding the bank's crypto-asset activities. The letter recounts that the bank notified the FDIC in May 2022 of its intent to offer crypto-asset buy, sell, and hold services to customers in response to FIL-16-2022, "Notification of Engaging in Crypto-Related Activities." The FDIC subsequently held discussions with bank executives, requested that the bank delay expansion of crypto-asset services, and sent a request list for additional information. Although the bank provided some responses, during a March 2023 phone discussion, the bank's President/CEO indicated that expansion of crypto-asset activity was no longer a top priority and that the remaining requested items would be submitted when management was ready to proceed. The FDIC requests that the bank keep them updated on plans concerning crypto-asset activity prior to pursuing them.
Bank Pauses Crypto Services Plan	2023-06-20	Kansas City Regional Office	This letter from the FDIC Regional Director acknowledges a bank's notification regarding its planned engagement in crypto-asset buy, sell, and hold services through a third party on the bank's online platform. The notification was provided pursuant to FIL-16-2022, which requires FDIC-supervised institutions to notify the FDIC about crypto-related activities. The FDIC requested information during an examination, and the bank provided details indicating the plans were preliminary and dependent on development progress by a third party. Through subsequent conversations, the FDIC learned that development had stalled. The letter acknowledges the bank's decision to indefinitely pause pursuing the proposed crypto-related activities and requests notification if the status changes.
Crypto Deposit Activities Risk Assessment	2023-06-28	Dallas Regional Office	This document is a letter from the FDIC to a bank's Board of Directors regarding findings from an April 4, 2023 visitation that focused on the bank's proposed deposit activity with a crypto-related entity. The letter describes the bank's plans to accept two deposit accounts from this entity - one for customer crypto-asset sales proceeds and another related to loans. The FDIC identifies significant risks in multiple areas including legal, accounting, operational, capital, credit, liquidity, reputation, AML/CFT, and consumer protection. The document includes detailed recommendations in Appendix A covering due diligence, planning, risk assessment, contingency planning, and policy revisions that the bank must address before proceeding with the relationship. The FDIC notes that the bank may need significantly more capital and liquidity if deposits must be held on-balance sheet, and reminds the Board of their responsibilities to properly manage risks.
Follow-Up Inquiry on Cyber-Asset and NFT Investment	2023-06-29	San Francisco Regional Office	This letter from the FDIC Regional Director responds to a bank's February 27, 2023 submission regarding crypto-related activities. The FDIC acknowledges the bank's response to previous request letters dated December 29, 2022, and November 2, 2022, which sought information about the bank's involvement with crypto-assets and NFTs. The bank had characterized these holdings as immaterial marketing activities rather than investments and stated it had ceased crypto-related activities, though it continues to hold the assets. The FDIC requests additional documentation within 30 days, including a legal analysis on the permissibility of holding these assets, clarification on NFT marketing usage, explanation for continued holding of these assets despite ceasing activities, and a risk assessment. Alternatively, the bank may provide a divestiture plan. The letter references Part 362 of FDIC Regulations, section 24 of the Federal Deposit Insurance Act, and FIL-54-2014 regarding documentation procedures for state banks.
Bank Exits Crypto Trust Role	2023-07-03	Chicago Regional Office	This document contains correspondence regarding a bank's notification to the FDIC about ceasing its involvement with cryptocurrency. The bank informs the FDIC that it has received trustee resignation paperwork for a trust that held cryptocurrency, effectively ending the bank's connection to crypto-related activities. The correspondence indicates that the bank had been working toward a June 30th target date for closure of the trust, with assistance from an attorney to complete the resignation process. The FDIC had been monitoring this situation, with personnel from Chicago and DC involved in the oversight. The document also references a previous inquiry from the bank regarding pass-through and escrow accounts that was directed to FDIC insurance personnel.
Bank's Crypto Account Closures	2023-07-12	San Francisco Regional Office	This letter from the FDIC acknowledges a bank's notification about its engagement with a crypto company for deposit account services and the subsequent decision to close those accounts. The FDIC requests specific information regarding the bank's risk assessment of crypto-related activities, including account details, due diligence documentation, third-party review reports, and board minutes. The letter references the Joint Statement on Crypto-Asset Risks to Banking Organizations (FIL-01-2023) and FIL-16-2022 regarding notification requirements for crypto-related activities. The FDIC instructs the bank to provide the requested information within 45 days and advises management to be more proactive and timely in notifying the FDIC about new crypto-related activities, particularly when conducting due diligence or entering non-disclosure arrangements.
FDIC Email Exchange on Crypto Activity Oversight	2023-07-23	San Francisco Regional Office	This document contains internal FDIC email correspondence discussing the review process for determining whether a bank's crypto-related activities fall within the scope of FIL 16-2022. The emails detail coordination between regional office staff and Washington Office (WO) regarding a draft memo and "out of scope" letter for a bank. The discussion includes recommendations for language in both the internal memo and the bank notification letter, with specific mention that the regional office believes the bank's activities do not fall within the scope of FIL 16-2022 based on information provided by the bank and reviewed during an ongoing DCP examination. The correspondence shows the review workflow involving multiple stakeholders before finalizing and sending the determination letter to the bank.
Crypto-Asset Risk Management Findings	2023-07-26	Atlanta Regional Office	This letter from the FDIC to a bank's Board of Directors transmits an examination report that includes findings related to the bank's proposed crypto-asset service. The FDIC identifies several "Matters Requiring Board Attention" concerning the bank's crypto-asset activities, including deficiencies in risk assessment, vendor due diligence, board oversight, and compliance management systems. The FDIC instructs the bank to implement corrective actions to address these matters before offering the new crypto-asset service. The letter notes that the bank had recently received notice that its service provider was terminating their agreement, which would alter the required corrective actions. The FDIC requests a written response from the bank within 45 days describing planned corrective actions.
MDI's Crypto Activities Out of Scope	2023-07-27	San Francisco Regional Office	This memorandum documents the FDIC's analysis of whether two crypto-related activities reported by a bank fall within the scope of FIL-16-2022. The bank proactively notified the FDIC on September 28, 2022, about relationships with two entities potentially involving crypto-related activities. For the first entity, the bank terminated the relationship on March 6, 2023, due to growing risks, and the FDIC determined this activity to be out of scope of FIL-16-2022. For the second entity, after examination by Compliance EIC, no evidence of digital asset involvement was found, resulting in a determination that this relationship was also outside the scope of FIL-16-2022. The FDIC plans to send an "Out of Scope" letter to the bank's board, reminding them to notify the Regional Director of any intent to engage in digital assets related activities.
Bank Resigns as Crypto Trustee	2023-08-08	Chicago Regional Office	This document is a final response from the FDIC to a bank regarding its notification of crypto-related activities. The bank had notified the FDIC about its crypto-asset activities pursuant to FIL-16-2022, which requires FDIC-supervised institutions to notify the FDIC about crypto-related activities. Following the notification, the FDIC requested additional information to assess safety and soundness, consumer protection, and financial stability implications. The bank subsequently informed the FDIC that it planned to resign as trustee for a trust that held crypto-assets, and later confirmed that it had resigned from this role. The FDIC acknowledges this change in status and requests notification of any future changes in this activity or other crypto-related activities.
Bank Ceases Crypto Partnerships	2023-08-08	Chicago Regional Office	This letter from the FDIC acknowledges a bank's notification about its intent to engage in crypto-related activities involving partnerships with entities using blockchain technology. The document outlines the sequence of interactions between the FDIC and the bank, including the bank's initial notification, the FDIC's request for additional information, and the FDIC's instruction that the bank refrain from providing certain services until the FDIC completed its review. The letter notes that the bank subsequently notified the FDIC that it would no longer proceed with the proposed crypto-related activities, and the FDIC acknowledges this change in status, superseding its previous instruction letter. The FDIC requests notification if the status of this activity or other crypto-related activities changes in the future.
Supervisory Feedback on Bank's Crypto Activities	2023-08-10	San Francisco Regional Office	This document is a supervisory feedback letter from the FDIC to a bank regarding its proposed crypto-related activities. The letter details the bank's notification to the FDIC about its plan to offer Bitcoin trading through its online banking platform via an arrangement with third parties. The FDIC conducted a review and identified numerous deficiencies in the bank's risk management, including inadequate Board oversight, insufficient policies and procedures, incomplete risk assessments, weak vendor due diligence, and an inadequate Compliance Management System. The letter expresses concerns about potential customer confusion between FDIC-insured deposit products and non-insured crypto products, and provides specific recommendations to strengthen consumer protection disclosures and risk management practices. The FDIC references several regulatory documents, including FIL-16-2022, the Joint Statement on Crypto-Asset Risks, and FDIC Part 328 regarding false advertising and misrepresentation of insured status.
FDIC Feedback Letter on Bank's Crypto Activities	2023-08-14	San Francisco Regional Office	This letter from the FDIC to a bank's Board of Directors provides supervisory feedback regarding the bank's crypto-asset activity involving a partnership with a third-party provider to offer bitcoin trading services to customers. The FDIC outlines numerous concerns with the bank's implementation, including inadequate risk assessments, limited due diligence processes, insufficient policies, unsupported financial projections, and compliance management system deficiencies that could lead to customer confusion about FDIC insurance coverage. The letter details specific weaknesses in the bank's approach to third-party risk management, consumer disclosures, and ongoing monitoring. The FDIC references relevant guidance including FIL-16-2022 and the Joint Statement on Crypto-Asset Risks. The letter notes that the third-party provider has since terminated the agreement with the bank, but the FDIC is providing feedback to inform future third-party risk management practices.
Bank Ends Bitcoin Services Agreement	2023-08-16	Chicago Regional Office	This document is a letter from the FDIC's Chicago Regional Office to a bank's Board of Directors acknowledging the bank's plan to terminate and unwind its agreement with a third party that allowed retail deposit customers to buy, sell, and hold Bitcoin through the bank's mobile banking platform. The FDIC notes receipt of the termination agreement, wind down plan with a 90-day liquidation period, and proposed customer notifications. The letter instructs the bank to maintain all records related to the wind down process, including termination benchmarks, account closure data, training materials, and customer complaints. The FDIC indicates that full implementation of the termination plan and resolution of a previously identified Matter Requiring Board Attention will be evaluated during an upcoming Safety and Soundness examination scheduled for the 4th quarter of 2023.
Bank Withdraws Crypto Activity Plans	2023-08-17	Atlanta Regional Office	This letter from the FDIC acknowledges a bank's notification regarding its intent to offer customers the ability to buy, sell, and hold crypto assets through its digital and mobile banking platform in partnership with another entity. The notification was provided pursuant to FIL-16-2022, which requires FDIC-supervised institutions to notify the FDIC about crypto-related activities. Following the notification, the FDIC requested information to assess safety and soundness, consumer protection, and financial stability implications, instructing the bank to refrain from providing these services until review completion. The letter notes that during a Joint Examination and in subsequent communication, the bank's Chief Risk Officer indicated they no longer intend to engage in the previously notified crypto activity, which the FDIC acknowledges, superseding their earlier letter. The FDIC requests notification if the status of this or other crypto-related activities changes in the future.
Crypto Activities Inquiry	2023-08-18	San Francisco Regional Office	This document is an FDIC letter requesting additional information from a bank regarding its crypto-related activities, specifically its engagement in blockchain-based digital records and relationship with a technology vendor. The letter references the bank's initial notification to the FDIC in response to FIL-16-2022, subsequent communications during a Safety and Soundness examination, and the FDIC's previous request for information. The attachment contains 42 detailed requests for additional information covering various aspects of the bank's crypto-related activities, including settlement records, project plans, legal analyses, policies, technical documentation, risk assessments, and details about the blockchain platform, wallet functionality, and relationships with third parties. The FDIC requests a response with supporting documentation within 60 days.
FDIC Emails on Crypto Bank Account Management	2023-08-30	San Francisco Regional Office	This document contains email correspondence between a bank and the FDIC regarding the bank's relationship with a crypto-related entity. The emails document the bank's decision-making process about opening accounts for this entity, including notification to the FDIC that the bank had closed existing accounts and transferred funds to another institution. The correspondence shows that after conducting enhanced due diligence, the bank ultimately decided not to open new accounts for the crypto entity unless significant structural changes occurred at the company. The emails also reference that the entity had become a "crypto only platform," which the bank noted as a significant change affecting the risk profile of the potential relationship.
FDIC-Bank Email Exchange Indicating No Change in Crypto Strategy	2023-09-11	Unknown	This document contains an email exchange between an FDIC Case Manager and a bank CEO regarding crypto-related activities. The FDIC representative follows up with the bank to determine if there have been any changes to the bank's strategy regarding crypto-related products, referencing a previous statement from the last examination that the "bank has no immediate plans to implement any crypto related products or services." The bank CEO responds confirming that there has been no change to their strategy regarding crypto.
Bank's Bitcoin Activity Review	2023-09-15	Dallas Regional Office	This letter summarizes findings from a joint FDIC and state regulator visitation of a bank that had launched bitcoin facilitation activities through its online banking platform in partnership with third parties. The visitation identified several deficiencies in the bank's risk management framework, including an inadequate risk assessment that lacked independence and failed to consider key risks, inconsistent customer-facing disclosures that did not clearly distinguish between insured deposits and non-insured crypto products, limited due diligence analysis of the third-party provider, and insufficient policies and procedures. The letter notes that the third-party provider terminated its agreement with the bank during the examination process, and requests documentation of the wind-down plan implementation. The letter references several relevant Financial Institution Letters (FILs) related to crypto activities, including FIL-16-2022 on notification requirements and FIL-35-2022 on deposit insurance and dealings with crypto companies.
Feedback on Proposed Bitcoin Service	2023-09-18	San Francisco Regional Office	This letter from the FDIC Regional Director provides supervisory feedback to a bank regarding its proposed Bitcoin trading service through its online banking platform. The FDIC conducted a review following the bank's response to an Additional Information Request letter and a limited scope examination. The letter identifies several underdeveloped aspects of the bank's risk management framework for the proposed crypto activity, including incomplete policies/procedures, outdated risk assessments, lack of signed contracts with the vendor, absence of crypto-related activities in audit plans, undeveloped AML/CFT controls, and incomplete customer interface/disclosures. The FDIC references several Financial Institution Letters (FILs) as resources, including FIL-16-2022 on notification of engaging in crypto-related activities, and requests notification of any material developments related to the proposed service, emphasizing that appropriate risk and compliance frameworks must be in place before implementation.
Bank's Blockchain Vendor Change Meeting	2023-09-22	Dallas Regional Office	This letter from the FDIC to a bank's Board of Directors acknowledges a meeting where the bank's Chief Innovation Officer and CEO outlined substantial proposed changes to their distributed ledger technology framework. The changes include plans to select a new vendor to move to a private, permissioned blockchain with centralized validation and without a native token, gas fees, or connectivity with non-bank ecosystems. In response to these changes, the FDIC requests an updated notification with detailed descriptions of the proposed solution and activities, as well as responses to previously requested information that reflect these changes. The FDIC also requests an updated project timeline, project plan, and testing proposal, noting that they will not provide follow-up requests or supervisory feedback related to the previous notification until receiving this updated information.
Bank's Crypto Activities Under Review	2023-10-06	Dallas Regional Office	This letter from the FDIC to a bank's Board of Directors summarizes findings from a joint examination team visitation that reviewed the bank's crypto-related activities. The document details how the bank initiated a digital service through a third party that allowed retail deposit customers to buy, hold, and sell Bitcoin through the bank's online banking platform. After becoming aware of this activity, the FDIC requested notification and a pause on new customer onboarding. The examination found significant deficiencies in the bank's risk management and compliance frameworks, including inadequate Board oversight, insufficient due diligence, lack of formal policies and procedures, absence of crypto-specific risk assessments, and no formal monitoring processes. The letter also identifies an apparent violation of FDIC Part 328 regulations regarding the use of the FDIC official advertising statement in advertisements for non-deposit Bitcoin products. The FDIC requests documentation about the wind-down plan following the third party's termination of its agreement with the bank.
Divest Crypto Assets by Year-End	2023-10-11	San Francisco Regional Office	This letter from the FDIC Regional Director acknowledges receipt of a bank's response to a previous FDIC letter regarding crypto-related activities. The FDIC notes that the bank intends to divest all crypto-related assets and non-fungible tokens (NFTs) by December 31, 2023, and will provide confirmation of the transaction to the FDIC and another entity once executed. The letter indicates the FDIC is awaiting this transaction confirmation and provides contact information for questions.
Bank Withdraws Crypto Activity Plan	2023-10-13	San Francisco Regional Office	This letter from the FDIC acknowledges a bank's notification regarding its intention to provide deposit accounts and related services to an existing customer operating in the crypto-asset space, as required by FIL-16-2022. The FDIC notes that after requesting additional information to understand the proposed activity, the bank's president later informed the FDIC that the bank was no longer pursuing the crypto-related activity and would notify the FDIC if it considers engaging in any crypto-related activity in the future. The letter references FIL-16-2022, which requires FDIC-supervised institutions to notify the appropriate FDIC Regional Director about activities involving or related to crypto-assets.
Bank Ceases Development of Crypto Asset Service	2023-10-31	San Francisco Regional Office	This letter from the FDIC to a bank's Board of Directors acknowledges the bank's notification that it is "no longer involved in virtual currency." The letter recounts the bank's history of engagement with the FDIC regarding crypto-asset services that would have allowed customers to buy, sell, and hold bitcoin, including initial discussions beginning in May 2021 and subsequent discussions from April 2022. The FDIC references FIL-16-2022, which required FDIC-supervised institutions to notify the FDIC about crypto-related activities, and notes that the FDIC had requested documentation about the bank's policies, processes, and controls for these activities. The letter states that the FDIC's previous instruction to refrain from expanding crypto services has been superseded due to the bank's cessation of crypto activities, and requests notification if the status of this or other crypto-related activity changes in the future.
Bank Halts Bitcoin Service Plans	2023-11-02	San Francisco Regional Office	This letter from the FDIC acknowledges a bank's notification about its plan to offer customers the ability to buy, sell, and hold bitcoin through online banking services. The notification was provided pursuant to FIL-16-2022, which requires FDIC-supervised institutions to notify the FDIC about crypto-related activities. The FDIC requested information to assess safety and soundness implications during a joint examination and asked the bank to refrain from expanding the service until review completion. The letter notes that the bank subsequently decided not to pursue the crypto-related initiative, superseding a previous FDIC letter, and requests notification if the status of this or other crypto-related activities changes in the future.
Bank Declines Crypto Customer	2023-11-13	San Francisco Regional Office	This document is an email to the FDIC San Francisco Regional Office regarding an interim bank contact with a bank CEO. During the call, the CEO reported that the bank's management decided not to proceed with a previously considered crypto relationship, noting that the customer found another bank. The CEO acknowledged the FDIC Case Manager's responsiveness to questions, though mentioned not having received feedback from the Washington Office before the decision was made to abandon the crypto relationship.
Misleading Crypto Insurance Disclosure Concerns	2023-12-21	Legal Division	This letter from the FDIC Legal Division addresses concerns about potentially misleading deposit insurance representations on a company's website. The FDIC attorney cites Section 18(a)(4) of the Federal Deposit Insurance Act and 12 C.F.R. Part 328, which prohibit misrepresenting FDIC insurance coverage. The letter states that the company's website may mislead consumers to believe that stock or crypto rewards are FDIC-insured when they are not, and fails to properly identify the insured depository institution where consumers' funds may be placed. The FDIC requests that the company revise its website to address these concerns by January 10, 2024, or provide supporting information if they believe their representations are accurate.
Bank's Crypto Account Monitoring Update	2023-12-22	San Francisco Regional Office	This document contains email correspondence regarding a bank's notification to the FDIC about opening a new account for a digital asset exchange. The bank informed the FDIC that they opened a business checking account for the exchange's business operations only, not for crypto wallet transactions or exchanges. The bank implemented several guardrails for the relationship, including ongoing monitoring by the BSA officer and relationship manager, requirements for documented approval for balance increases above certain thresholds, and board executive committee approval for larger relationships. The FDIC's regional office is preparing an acknowledgment letter with a request list to verify that the funds in the account are corporate funds. The notification was made in accordance with FIL-16-2022.
Exam Findings and Termination of Crypto Activities	2024-01-26	Atlanta Regional Office	This letter from the FDIC Regional Director addresses the resolution of Matters Requiring Board Attention (MRBA) related to a bank's previously notified crypto-related activities. The bank had informed the FDIC of its intent to engage in crypto-related activities through its core service provider in response to Financial Institution Letter 16-2022. The FDIC requested the bank refrain from providing the service pending review and conducted an examination that identified deficiencies in the bank's risk management framework, including inadequate policies for assessing third-party relationships, limited risk assessment, and insufficient vendor due diligence. The MRBA were subsequently closed after the bank notified the FDIC that its service provider was terminating their agreement and the bank confirmed closure of all test accounts. The letter supersedes a previous FDIC communication and requests notification of any future changes in crypto-related activities.
Bank's Crypto Activities and CIP Compliance	2024-01-29	Unknown	This memorandum summarizes a meeting between FDIC Regional Office personnel and bank management to discuss CIP procedures and liquidity risk management. The bank confirmed it ceased originating new secured loans and discussed its CIP collection procedures, where it collects the last four digits of customer TINs through third-party partnerships and obtains the remaining digits through other channels before account opening. Bank management referenced OCC exemptive relief to support this practice, but FDIC representatives clarified that current rules require obtaining all nine TIN digits directly from customers prior to account opening. The meeting also addressed the bank's liquidity risk management related to significant digital asset-based deposits, with FDIC emphasizing the importance of Board oversight, policy development, and regular monitoring of deposit concentrations. Bank management committed to expanding Board meeting minutes and providing additional documentation.
Bank Ends Crypto Partnership	2024-03-05	Chicago Regional Office	This letter from the FDIC to a bank's Board of Directors accompanies a Report of Examination and discusses the bank's previous crypto-related activities. The letter notes that the bank had offered a cryptoasset service through a third party that allowed customers to buy, sell, and hold Bitcoin. The FDIC had previously requested the bank not expand this service pending review and provided supervisory feedback about weaknesses. The bank subsequently notified regulators that it had decided to end the partnership with the third-party provider, sold customers' Bitcoin holdings, and closed the accounts. The FDIC acknowledges this change in status, considers the Matter Requiring Board Attention (MRBA) closed, and supersedes its previous letter regarding crypto activities. The FDIC requests notification if the bank's status regarding crypto-related activities changes in the future.
FDIC Letter Requests Crypto Activity Clarification	2024-03-08	San Francisco Regional Office	This document is a letter from the FDIC's Regional Director to a bank CEO regarding the bank's notification of engagement with crypto-related companies. The FDIC acknowledges receipt of the bank's June 16, 2023 notification about engagement with additional crypto-related companies in response to Financial Institution Letter 16-2022. Due to inconsistencies identified in a prior examination between described purpose and actual activities within the merchant processing function, the FDIC requests additional information about the bank's crypto-related activities. The letter includes an attachment with specific questions about the companies' deposits, due diligence performed, risk assessments, service descriptions, payment types, transaction volumes, and details about partnerships. The bank is given 45 days to respond with the requested information and documentation.
Bank's Bitcoin Service Changes	2024-03-18	Dallas Regional Office	This document is a letter from the FDIC's Dallas Regional Office to a bank's Board of Directors regarding the bank's crypto-related activities. The letter acknowledges the bank's notification about offering bitcoin services through a third party, which began in February 2022. Following the FDIC's issuance of FIL-16-2022 requesting notification of crypto-related activities, the FDIC asked the bank to refrain from expanding its bitcoin service while the FDIC assessed the implications. The bank agreed to this request and later notified the FDIC that the third-party provider terminated their agreement, leading the bank to discontinue the service and allow customers to liquidate their accounts. The FDIC acknowledges the bank's updated status, supersedes its previous letter, and requests notification of any future changes to this or other crypto-related activities.
FDIC Letter Critiques Blockchain Approach and Seeks Meeting	2024-03-19	San Francisco Regional Office	This letter from a bank to the FDIC Regional Director supplements the bank's previous response to an FDIC request for additional information regarding the bank's relationship with an unnamed entity. The bank references its history of communications with the FDIC, including its original notification to the FDIC about its activities, and subsequent responses to FDIC information requests. The letter quotes extensively from FDIC Vice Chairman Travis Hill's recent remarks distinguishing between cryptocurrency and the use of distributed ledger technology by banks. The bank emphasizes that its blockchain will be used as a distributed ledger technology rather than cryptocurrency, and requests a meeting with the FDIC to discuss its current and planned activities.
Bank's Crypto Activities Unchanged	2024-06-21	Atlanta Regional Office	This document contains an email exchange between an FDIC Case Manager and a bank representative regarding follow-up inquiries about the bank's crypto-related activities. The FDIC is following up on previously reported crypto-related activities, which included DDA accounts with crypto pass-through transactions (approximately 250 transactions per month, less than 1% of total activity, primarily through a redacted entity) and a single commercial loan to a client where no crypto was taken as collateral. The bank representative confirms that there have been no changes to the bank's crypto-related activities since the last report. The exchange references FIL 16-2022 relating to crypto-related activity.
Bank Divests Crypto Assets	2024-06-24	San Francisco Regional Office	This letter from the FDIC acknowledges a bank's notification regarding its purchase and holding of crypto-related assets and non-fungible tokens (NFTs), which was provided pursuant to FIL-16-2022. The document outlines a series of interactions between the FDIC and the bank, including multiple requests for additional information and clarification from the FDIC and subsequent responses from the bank. The letter notes that the bank has since provided documentation reflecting its divestiture of crypto-related assets and NFTs, which the FDIC acknowledges. The FDIC states that its review of the bank's notification is now complete and requests that the bank notify the FDIC if the status of this activity or other crypto-related activity changes in the future.
Concerns on Bank's Stablecoin Reserves	2024-07-23	New York Regional Office	This letter from the FDIC to a bank's Board of Directors provides supervisory feedback regarding the bank's notification to maintain stablecoin reserves. The bank had submitted notification pursuant to FIL 16-2022, "Notification of Engaging in Crypto-Related Activities," proposing to hold U.S. dollar deposits corresponding to a stablecoin issuance. The FDIC identifies deficiencies in the bank's risk assessment, noting it inadequately addresses liquidity impacts from end-user activity and crypto-asset volatility, lacks controls to prevent reserve funds from being used in operations, and fails to properly address compliance risks. The FDIC concludes that weaknesses in liquidity and compliance risk management prevent the bank from conducting the proposed crypto-related activity in a safe, sound, and compliant manner at this time.
Crypto Project Phase II Feedback	2024-07-24	San Francisco Regional Office	This memorandum summarizes a meeting between FDIC representatives and bank management regarding the bank's desire to proceed with Phase II of a crypto-related activity. The FDIC provided feedback on several areas including adherence to the bank's Code of Ethics Policy, particularly regarding recusal of insiders with personal interests; the need for management to stay informed about federal and state securities laws governing blockchain technology transactions; revisiting contractual arrangements with a third party; and addressing inconsistencies in requirements and systems development documentation. The FDIC required a written response within 45 calendar days addressing supervisory considerations, risk identification and controls, and implementation plans for Phase II, and requested re-engagement before Phase III implementation. Bank management agreed to respond within the timeframe.
Bank's Crypto Activities Review	2024-08-13	Kansas City Regional Office	This document contains email correspondence regarding a consultation about a bank's crypto-related activities. The bank had notified the FDIC of its intent to offer crypto-asset products and services through a Banking-as-a-Service (BaaS) arrangement, and subsequently began offering users the ability to purchase and sell crypto-assets like Bitcoin and Ethereum through its mobile application. The FDIC conducted a review and identified a Level 2 Medium Severity Violation of FDIC Part 328.102(a) for advertisements that failed to include clear disclaimers that crypto-asset products were not FDIC-insured. The consultation was closed with instructions to follow up during the next compliance examination to determine if the bank had corrected the deficiencies noted in the Report of Examination.
Bank's Crypto Activity Notification	2024-08-28	Dallas Regional Office	This document is a response from the FDIC's Dallas Regional Office to a bank's notification about its intent to engage in crypto-related activities, specifically regarding XXXXX that may hold cryptocurrency. The letter acknowledges receipt of the notification provided pursuant to FIL-16-2022 "Notification of Engaging in Crypto-Related Activities," which requires FDIC-supervised institutions to notify their Regional Director about crypto-asset activities. The FDIC requests additional information and documentation to better assess the bank's proposed activities, though the specific information requested is redacted in the document. The letter provides instructions for submitting the requested information through the FDIC's Secure Email portal.
Bank Halts Crypto Payment System	2024-10-24	New York Regional Office	This letter from the FDIC acknowledges a bank's notification regarding its potential indirect participation in a proof of concept exercise for shared ledger technology to settle tokenized central bank money, commercial bank money, and Treasury securities through the Regulated Settlement Network. The notification was provided pursuant to FIL 16-2022, "Notification of Engaging in Crypto-Related Activities." The FDIC notes that the bank subsequently informed them that the organization involved is liquidating and has ceased development of the proposed payment system. The FDIC states that their review is complete and prior correspondence is superseded since the bank is no longer proposing to engage in the proof of concept exercise. The letter requests that the bank notify the FDIC if the status of this activity or other crypto-related activity changes in the future.
Feedback on Bank's Crypto Activities	2024-10-29	San Francisco Regional Office	This letter provides supervisory feedback from the FDIC to a bank regarding its crypto-related activities. The bank had previously notified the FDIC of partnerships with two third parties for crypto-related services, including a credit card product with crypto rewards and money market accounts for crypto platform users. The FDIC outlines several concerns about the bank's XXXXX partnership, including insufficient due diligence, ambiguity in the rewards program regarding crypto-asset custody, potential undisclosed account openings through the User Agreement, and contradictory statements in the compliance risk assessment about resource adequacy. The letter references several regulatory documents, including FIL-16-2022 on notification requirements, FIL-35-2022 on deposit insurance, the Joint Statement on Crypto-Asset Risks, and Part 328 of FDIC regulations regarding false advertising. The FDIC requests the bank to address these issues and provide a written response within 45 days.
Crypto-Focused Bank Examination 2024	2024-10-31	Chicago Regional Office	This examination planning memorandum outlines the FDIC's upcoming examination of a bank that has initiated the process to begin working with a crypto exchange and is seeking regulatory approval for such a partnership. The document details that the bank added a Fintech customer in 2024 which expanded cash and ACH activity related to companies, and both the crypto exchange and this Fintech added non-interest bearing deposits. The memo notes that the bank's risk profile is increasing due to several factors including the planned entry into crypto markets. The Emerging Technology Group will be conducting a concurrent review of management's proposed relationship with the crypto asset exchange, and the bank has recently notified the FDIC of its planned engagement in crypto-related activities. The examination will focus on the bank's risk management practices, particularly regarding third parties and new services.
Bank's Crypto Service Proposal Review	2024-11-19	Chicago Regional Office	This document is a letter from the FDIC Regional Director acknowledging a bank's notification about its intent to offer a third-party authorization verification service for customer transactions in crypto-assets ("TPS Service"). The letter outlines the FDIC's review process, including document reviews and information requests made to the bank between February 2023 and January 2024, followed by a full-scope examination in March 2024. During the examination, the FDIC learned that the bank had only completed due diligence on potential customers/vendors and had not commenced crypto-related activities. The letter notes that in a September 2024 meeting, the bank's CEO indicated they were not actively pursuing the proposal, which was later confirmed by email. The FDIC considers its review complete but requests notification if the status of this or other crypto-related activities changes in the future.
Bank Halts Crypto Activities Plan	2024-12-17	San Francisco Regional Office	This letter from the FDIC responds to a bank's notifications about engaging in crypto-related activities. The bank had notified the FDIC in May and August 2022 of its intent to engage in various crypto activities including issuing stablecoins, providing digital asset custody services, originating loans collateralized by digital assets, and facilitating customer transactions with digital assets. The FDIC had requested additional information and asked the bank not to proceed with planned activities pending supervisory feedback. The letter acknowledges that the bank subsequently informed the FDIC in May 2024 that it had decided to eliminate proposed crypto activities from its business plan. The FDIC confirms that its review of the bank's notifications pursuant to FIL-16-2022 is complete and requests notification if the status of crypto-related activities changes in the future.
Bank's Crypto Activities Update	2025-01-27	Kansas City Regional Office	This letter from the FDIC responds to a bank's notification about crypto-related activities. The bank had previously notified the FDIC about beta testing a bitcoin buy/sell/hold offering, plans for a bitcoin debit card rewards program, and a loan secured by bitcoin. The FDIC had requested the bank refrain from expanding its bitcoin offering until review completion and later requested additional information to assess safety and soundness implications. The bank subsequently informed the FDIC that the bitcoin buy/sell/hold offering and rewards programs were no longer priorities, and later confirmed that the bitcoin-secured loan had been paid off and no additional crypto-related activities were planned. The FDIC acknowledges this updated status, notes that its previous letter has been superseded, and requests notification of any future changes to crypto-related activities.
Crypto Activities Information Request	Unknown date	Unknown	This document is a request for information related to a bank's crypto-related activities, specifically involving Bitcoin transactions through a partnership with an unnamed entity. The request contains 17 detailed items seeking documentation about contracts, settlement processes, permissibility analysis, risk assessments, transaction limitations, marketing materials, board minutes, policies and procedures, oversight responsibilities, and strategic planning related to the crypto activities. The items focus on understanding the bank's implementation, risk management, compliance framework, and financial analysis of its crypto offerings, including its assessment of SEC SAB 121 applicability and cost-benefit analysis of the partnership.
Crypto-Asset Due Diligence Requests	Unknown date	Unknown	This document is an attachment listing seven outstanding request items related to a bank's crypto-asset activities. The requests seek information about due diligence on third parties, transaction and gas fees, blockchain utilization details, documentation confirming the bank is not acting as a custodian, project implementation plans, and AML/CFT policies. The document specifically mentions Token Payment Services (TPS) and requests clarification on which blockchains will be used, whether the service will operate with crypto-assets not associated with a redacted entity, whether privacy-enhancing blockchain technologies will be supported, and whether TPS will be provided for NFTs.
Inquiry on Crypto Deposit Accounts	Unknown date	Unknown	This document is a request list from the FDIC seeking information about a bank's digital asset related deposit accounts. The list requests detailed analysis of deposit volatility and liquidity risk management, board reporting, account listings with transaction volumes, and identification of accounts holding funds for digital asset firms' customers or functioning as stablecoin reserves. For accounts serving these functions, the FDIC requests account agreements, disclosures, marketing materials, policies for reviewing third-party materials using the bank's name or referencing deposit insurance, processes for maintaining records of user funds subject to FDIC pass-through insurance disclosure, and any role in verifying stablecoin reserves. The FDIC also requests documentation of any analysis determining the accuracy of digital asset firm disclosures regarding FDIC pass-through deposit insurance.
Inquiry on Bank's Crypto Strategy	Unknown date	Atlanta Regional Office	This document is an email from an FDIC Financial Institution Examiner to a bank CEO following up on the bank's previous interest in crypto-related products and services. The examiner inquires about any changes in the bank's strategy regarding crypto products/services and requests information about any decisions or plans in this area. The email reminds the CEO to contact the Atlanta Regional Office before engaging in crypto-related activities, referencing FIL 16-2022 as guidance. The communication indicates that previous examinations and correspondence had shown some interest but no immediate plans for implementation of crypto-related activities.
Crypto Activity Acknowledgement and Request	Unknown date	New York Regional Office	This document is a request list from the FDIC regarding a bank's crypto asset activities. The list contains 25 items requesting detailed information about the bank's crypto-related operations, including contracts, transaction flows, settlement processes, permissibility analysis, vendor management documentation, consumer disclosures, fee structures, risk assessments, and activity volumes. The FDIC is seeking information about the bank's relationship with a third-party provider (whose name is redacted as "XXXXX"), including how customer accounts would be handled if services were discontinued. The list also requests board minutes, strategic plans, implementation details, policies and procedures, and information about consumer protections related to the crypto activities.
Crypto Activity Information Request	Unknown date	Unknown	This document is an attachment containing a detailed list of information requests from the FDIC regarding a bank's proposed crypto-related activities with a redacted third party. The requests cover multiple aspects of the relationship including an overview of the relationship structure, digital wallet management, customer journey screens, virtual ledger details, data and funds flows, deposit volatility analysis, risk assessments, policies and procedures, contracts, transaction volumes, due diligence documentation, and compliance controls. The document also requests specific information about AML/CFT compliance systems, fraud prevention mechanisms, consumer protection measures, and API controls related to the crypto activities. The comprehensive nature of the requests suggests the FDIC is conducting a thorough review of the bank's proposed crypto operations.