6 10, 2022


2022-10-06T17:22:24-04:00October 6th, 2022|2- Daily Briefing|

OSTP Establishes AI User Rights, Privacy Protections

The White House Office of Science and Technology Policy (OSTP) has released a little-noticed AI “Bill of Rights” that establishes AI user rights and data privacy principles.  Although nonbinding, this framework now sets policy that individual agencies are likely to follow even if they are nominally independent, as is the case with the FRB, OCC, and FDIC.  The CFPB is no longer independent and is in any case already committed to like-kind principles; the banking agencies so far have only issued an RFI (see FSM Report AI).

OCC Tightens Fintech, Payment, Crypto Supervisory Screws

The OCC today released its Bank Supervision Operating Plan for FY2023, highlighting the Office’s supervisory issues based in part on policy considerations.  The agency is prioritizing cybersecurity; third-party service providers with a particular focus on fintechs; consumer-protection and AML compliance; new product risk, such as payment systems technology and digital assets; and climate risks.


9 03, 2022


2023-04-04T10:50:56-04:00March 9th, 2022|5- Client Report|

Biden Administration Decides Crypto Here to Stay, Seeks CBDC

We follow our initial client alert here with an in-depth analysis of President Biden’s long-awaited executive order laying down steps intended quickly to construct a U.S. digital-asset policy construct. Although sparked in part by virtual currency’s role in the Ukraine crisis, the executive order (EO) is a watershed event establishing for the first time that the U.S. views digital assets as a fixture of future finance warranting a rapid, far-reaching, and stringent set of governance, law-enforcement, equity, inclusion, and technology policy intervention. In general, the EO establishes a U.S. principle akin to that set by global regulators in this area: same-business same rules. Nothing in the order thus threatens SEC Chairman Gensler’s assertion that current law addresses many investor-protection challenges (see Client Report INVESTOR19) indeed, the EO strengthens the SEC’s hand by validating the chairman’s concerns.


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