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OCC Letter Affirms Nat'l Banks' Shield From State Licensing

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Christina Grigorian
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Dan Davis
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Carl Kennedy
Partner and Co-Chair, Financial Markets and Regulation

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Christina Grigorian
Partner, Deputy General Counsel and Chief Privacy Officer
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Dan Davis
Partner and Co-Chair, Financial Markets and Regulation
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Carl Kennedy
Partner and Co-Chair, Financial Markets and Regulation

National banks that hold deposits insured by the Federal Deposit Insurance Corp. are nearly always explicitly exempt from state licensing requirements related to consumer-facing activities like money transmission.

London, England, UK - 04 June 2025: An exterior view of the State Street, Barclays International (One Churchill Place Building), HSBC headquarters high-rise building (8 Canada Square Tower) in Canary Wharf, East London, UK. The modern glass and steel tower features the company’s signage displayed on its facade.

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Avatar
Christina Grigorian
Partner, Deputy General Counsel and Chief Privacy Officer
Avatar
Dan Davis
Partner and Co-Chair, Financial Markets and Regulation
Avatar
Carl Kennedy
Partner and Co-Chair, Financial Markets and Regulation

Get in touch

Avatar
Christina Grigorian
Partner, Deputy General Counsel and Chief Privacy Officer
Avatar
Dan Davis
Partner and Co-Chair, Financial Markets and Regulation
Avatar
Carl Kennedy
Partner and Co-Chair, Financial Markets and Regulation

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