364 safety-and-soundness standards and risk appetite statements. • Clarify permissibility for your charter and structure. “Permissible” is not blanket approval. Confirm legal authority under state law (for state nonmember banks) and Part 362, where applicable; map each proposed activity to legal authority and supervisory expectations. Keep board minutes and counsel memos current. • Engage your supervisory team proactively. FIL-7-2025 removes prior approval, not supervisory dialogue. However, a diligent product rollout will always require sharing your program design, controls, KPIs/KRIs and issues-management plan with your exam team. This preserves transparency and mitigates surprises during exams. Details of the plan are the key to successful regulatory buy-in, so reduce confusion by ensuring plain-language disclosures that distinguish insured deposits from crypto-assets and explain custody, segregation and loss scenarios. The FDIC has pivoted from a 2022 posture that required prior notification and emphasized uncertainty to a 2025 framework that permits banks to engage in permissible crypto-related activities without prior approval, anchored in safety and soundness and compliance. For community banks, the opportunity is to pilot targeted use cases with proper risk-assessment controls, proactive supervisory transparency and consumer-centric clarity, while staying nimble as interagency guidance evolves. As always, our firm is happy to answer questions or provide guidance on this or any other subject. Please feel free to reach out to me or any one of our firm leaders should you have any questions. Ian is a firm principal at S.R. Snodgrass with expertise in all aspects of audit and assurance services. He is exceptionally proficient at assisting public companies in their SEC regulatory filings under the Securities Act of 1933, the Securities Exchange Act of 1934, and the Sarbanes-Oxley Act of 2002, and navigating through business combinations as well as public and private stock offerings. He is a member of the American and Pennsylvania Institutes of Certified Public Accountants (PICPA), PICPA Financial Institutions Committee and PICPA Council, and is a frequent speaker at numerous banking and accounting conferences. He was named in 2025 as one of America’s Top 200 CPAs by Forbes magazine. SOURCES https://www.fdic.gov/news/inactive-financial-institution-letters/2022/ fil22016.html https://www.fdic.gov/news/financial-institution-letters/2025/fdic-clarifiesprocess-banks-engage-crypto-related https://fdic.gov/news/press-releases/2025/fdic-releases-documentsrelated-supervision-crypto-related-activities TAKE US ANYWHERE! Scan to read the most recent publication. Stay up to date from your couch, office or even the moon! Place a 1” x 1” QR Code White on Black Here to the main website 22 WEST VIRGINIA BANKER
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