How do you build a bank? I know the Capital One story from having worked there. But how do you build a bank today? At @ModernTreasury we're taking a customer centric approach to our proposed national trust bank. We want to view things from your eyes and make sure your experience is top notch. We are taking that North Star — you, our customer — and aligning it with a twin star of compliance. Because if we can't do compliance right, you can't bank with us for very long. If you're someone who makes payments and banking decisions at your company — come chat with us! We're designing for folks like you and we want to hear your feedback. We know we still need to demonstrate we meet the OCC's standards and earn conditional approval, and then full approval after that. But we're confident in our application and are committed to doing what it takes to meet the bar the OCC sets for charter holders. In the meantime, we're taking all of the feedback we've gotten and will get and are doing tabletop exercises to spot our gaps. I'm excited for our session tomorrow where we step through "Three Customers Walk into the Bank." Have thoughts for us — get in touch with our team and make them heard. This is going to be your bank, too. Because at MT, we know our success starts with making our customers successful.

Four of the US’s biggest banks blocked outside AI agents from accessing customer accounts last week. The reason given was consumer protection and that’s reasonable up to a point. The rules around agent permissions and identity are still very early on and there is no clear answer on who is liable if something goes wrong when software is moving your money. It’s hard to look at this without also thinking about the business model that is being protected. Regular checking accounts are at 0.1% and the high yield accounts are at 3.3% to 5%. JPMorgan Chase, Bank of America and Wells Fargo have $1.6T in deposits earning nothing, and most of it stays put. They have their direct deposit, their bills are on autopay and they’ve had it like that for years. They don’t care that much to move for a better rate. An agent won’t have that inertia. If it can get you another 2% somewhere else and you’ve given it the go-ahead to do so, it will. It doesn’t care how long you’ve been with the bank or whether you like the app. The challenge for banks is to compete on what the software can see at a glance: the terms, the trustworthiness, the availability and the ease with which money can move. That in turn puts a squeeze on the system underneath. A great deal of banking still runs on batch processing and settlement periods. To support agents, a bank needs to know who the agent is acting for, what it’s authorized to do, and whether a transaction is approved at the point it occurs. Live balances and a robust audit trail have to become the norm. Embedding that in an existing bank is a massive undertaking. I also think there’s a very strong case for this being a consolidation rather than a fragmentation of banking. Integrations are expensive and time consuming and routing funds within the same platform is far easier. The more activity you have on a platform the better your cash flow data and the easier it is to underwrite and therefore to get business. You could end up with a small number of platforms designed for agents taking a huge proportion of that activity. Community banks may find the investment too high and the mega banks have the scale but also the legacy systems to work through. Regulation will be a long time coming. Much of the current thinking is based on the 1978 EFTA, so the companies that are running the agents in production today will be the ones that determine the default answers on liability, authorization and identity. Blocking agents gives the banks some time, but I don’t see it as a sustainable solution. What I’m more interested in is what happens in the interim. Will the banks actually go on to make the changes they need to, or will the platforms that the agents prefer end up being built by someone else?

FinCEN Proposes to Rewrite the AML Program Rule Around One Question: Does Your Program Actually Work? okt.to/iPvCI3 via @@mikevolkov20

Federal Reserve Board announces termination of enforcement actions with Gardner Bancshares, Inc. and Small Business Bank For release at 11:00 a.m. EDT federalreserve.gov/

OCC moved stablecoins from policy debate toward operating rules. On October 21, it finalized GENIUS Act rules for permitted and foreign payment-stablecoin issuers under its jurisdiction, covering reserve backing, redemption and risk management. The rule and Act take effect January 18, 2027. This does not make compliance automatic: BSA, AML and OFAC provisions remain for separate rulemaking. The advantage now shifts toward issuers and infrastructure providers that can turn controls into routine operations—custody, reporting and reliable redemption. Source: OCC — October 21, 2026⁠ #Stablecoins #DigitalAssets #Payments #Regulation

Tokenized deposits just went retail. SoFi's SOFIE pays 4.40% and carries FDIC coverage until you convert it into a stablecoin. For US community banks and credit unions the question is not crypto. It is whether your deposits can move at the same speed. #Auditrol

Community banks deserve advanced tools to keep their operations safe. Through Daybreak for Frontline Defenders, we’re partnering with @ICBA to help community banks access AI-powered cyber defenses—and the training and support to use them. icba.org/w/icba-openai-annou…

Federal bank regulators used four notices and 12 rule categories in a decennial review, but GAO found no documented criteria for deciding what to change. whatsthescoopwithbroach.com/… #Banking #Regulation Photo: FDIC · public domain

Regulators are tweaking north & south of the $10 billion line, lightening the burdens of what #bankers say became a #regulatory approach too focused on process, not #risk. bankdirector.com/article/reg…

Read the OCC’s enforcement actions for October at occ.gov/news-issuances/news-….

A routing glitch, a stale watchlist, one dismissed alert — coincidence or a broken system? OFAC’s $11.6M Bank of America case says dig deeper. Read Part 3 now & subscribe for daily compliance insights: bit.ly/3UzXq9g #ComplianceTraining #OFACCompliance #RiskManagement

Newly released resources from the #CSBS & the #NYSDFS may be the start of increased guidance regarding the use of #AI in state-chartered #banks & other state-regulated #financial institutions. bankdirector.com/article/wha… @dinsmore_shohl