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Logan advises clients on the requirements, impact, and implementation of financial regulation, with a focus on regulatory issues related to digital assets, cryptocurrency, and digital banking. His clients include financial institutions, fintech firms, startups, and tech companies.

Financial technology firms and certain banks and bank holding companies can expect to face increased scrutiny as the Board of Governors of the Federal Reserve System takes another step to stem risks related to crypto-assets, use of blockchain technology, and complex fintech partnerships with nonbanks to deliver financial services to customers. Through its newly announced Novel Activities Supervision Program (“NAS Program”), the Federal Reserve will be taking a harder look at its supervised banking organizations, even those with less than $10 billion in assets, “to ensure that the risks associated with innovation are appropriately addressed” in four key areas:Continue Reading The Federal Reserve’s Novel Activities Supervision Program: What Banks and Nonbanks Need to Know

The Federal Reserve Board, on August 15, 2022, issued final guidelines for regional Reserve Banks to use when considering applications for Federal Reserve “master accounts”—deposit accounts that enable direct access to the Federal Reserve’s payment systems and provide critical infrastructure to financial institutions operating in the United States. The final guidelines comprise a set of