Federal Reserve told supervised banks to notify it before pursuing crypto activities

The Federal Reserve Board on August 16, 2022, issued SR 22-6/CA 22-6, directing every banking organization it supervised—including organizations with $10 billion or less in consolidated assets—to notify its lead Federal Reserve supervisory contact before engaging in crypto-asset-related activity.

Organizations that were already conducting such activity were told to notify their supervisory contact promptly if they had not done so. The letter converted the Federal Reserve’s broad concern about digital assets into a concrete supervisory process, but it neither authorized nor prohibited any particular crypto service.

What banks were expected to demonstrate

Before beginning a crypto-asset activity, a supervised banking organization had to determine whether the activity was legally permissible and whether federal or state filings were required. The Federal Reserve identified potentially relevant statutes including the Bank Holding Company Act, Home Owners’ Loan Act, Federal Reserve Act and Federal Deposit Insurance Act.

The letter’s examples of covered activity included crypto-asset safekeeping and traditional custody, ancillary custody services, facilitating customer purchases and sales, lending secured by crypto assets, and issuing or distributing stablecoins. That list was illustrative rather than exhaustive.

Banks were also expected to establish systems capable of identifying, measuring, monitoring and controlling the associated risks on an ongoing basis. The Federal Reserve specifically identified operational and technology failures, hacking, fraud, theft, third-party relationships, financial and legal exposure, Bank Secrecy Act compliance, anti-money-laundering controls, sanctions compliance and consumer-protection obligations.

Stablecoins received particular attention because the agency said large-scale adoption could create run risk and disrupt payment systems. The letter nevertheless made no finding about any named stablecoin, bank or transaction.

Federal Reserve staff said they would provide relevant supervisory feedback as appropriate and in a timely manner. State member banks were separately encouraged to notify their state regulators before undertaking crypto activity.

A widening federal supervisory perimeter

The August 16 letter placed the Federal Reserve alongside other federal banking regulators that had moved from general crypto warnings toward institution-level notification procedures. On November 23, 2021, the Office of the Comptroller of the Currency said national banks and federal savings associations could conduct certain previously recognized cryptocurrency, distributed-ledger and stablecoin activities only after notifying their supervisory office and receiving written notice of non-objection.

The Federal Reserve’s formulation was not identical. SR 22-6 required legal analysis, controls and advance notification, while saying supervisors would provide feedback; it did not expressly create the same written non-objection condition described by the OCC.

The timing also mattered. On August 15, 2022, the Federal Reserve had finalized a risk-based framework for evaluating requests for Reserve Bank accounts and payment services, including requests from institutions with novel charters or activities. Taken together, the two releases addressed different institutional gates: access to Federal Reserve payment infrastructure and the conduct of crypto activity inside supervised banking organizations. Neither release guaranteed account access or blanket permission to offer crypto products.

What the record did not establish

SR 22-6 was supervisory guidance, not an enforcement order, license or crypto-specific capital rule. It announced no penalty, named no bank and supplied no deadline for the Federal Reserve to accept or reject a proposed activity. The defensible August 16 interpretation is procedural: crypto initiatives at supervised banks were expected to undergo legal and risk review before launch.

Later administrative context

The Federal Reserve withdrew SR 22-6/CA 22-6 on April 24, 2025. That later withdrawal changes the guidance’s current status but not what the August 16, 2022, record communicated to supervised banks.