On April 24, 2025, the Federal Reserve Board (the “Board”) announced the withdrawal of its prior guidance requiring state member banks to notify supervisors in advance of engaging in crypto-asset activities. Previously, under Supervisory Letters SR 22-6 and SR 23-8, the Board imposed notification and review processes for banks exploring crypto-related activities. These procedures involved the need for state member banks and bank holding companies to obtain a formal “supervisory non-objection” before participating in activities involving crypto-assets. Following the withdrawal of these supervisory letters, the Board is displaying a shift in tone toward a more innovation-forward posture regarding crypto-assets in the traditional banking sector.
Takeaway
This announcement is significant given the Board’s historically skeptical approach to digital assets. Although the shift away from mandatory pre-approvals for crypto-activities is noteworthy and provides more autonomy to banks to explore digital assets, banks must now treat crypto activities similar to other assets with minimal guidance from the Board on how to approach this analysis. Banks should familiarize themselves with the relevant regulatory requirements and continue to monitor announcements from the Board for further guidance.
