• T Skevington and M Bacina

Coinbase CLO converts to currency Comptroller


Brian Brooks, former Chief Legal Officer at Coinbase, has become the acting Comptroller of Currency at the United States' Office of the Comptroller of the Currency (OCC). The OCC is America's regulator and supervisor for all US national banks, federal savings associations and federal branches or agencies of foreign banks.


In a statement following his appointment, Brooks outlined his commitment to innovation, saying:

We should approach our work not just with an eye to the next year, but to ensure the federal banking system adapts to the changing needs of consumers, markets, and the nation for the next 50 or 100 years.

To that end, Brooks laid out four priorities for the OCC moving forward, including:

  1. Build upon responsible innovation to help the banking system keep up with changes in the way American consumers and businesses manage their finances.

  2. Enhance the strength of the federal banking system by enhancing the scope and relevance of the national charter.

  3. Ensure banks serve their entire community through fair access to credit, capital, and financial services.

  4. Provide OCC employees engaging, rewarding, and challenging career opportunities.

While Brooks' statement avoids specifically mentioning blockchain or digital currency, the above priorities certainly bear some similarity to many of the fundamental principles in the blockchain and digital currency space.


Since becoming acting Comptroller, Brooks has more explicitly reaffirmed his views on blockchain and digital currency, saying at Consensus: Distributed:

Increasingly, it looks a lot like crypto is banking for the 21st century.

and

one of my messages in my new role is going to be to remind my colleagues at the OCC that banks not only have the ability, they have an obligation to serve all lawful businesses. They shouldn’t be discriminating because something’s a new technology.

Brooks has taken the role following former Comptroller Joseph Otting's resignation, which was announced just one day after the OCC released its final rule on “strengthening and modernizing” the Community Reinvestment Act (CRA), which among other things requires banks to meet the credit needs of all communities they serve.


Brooks joined the OCC from Coinbase, Inc., where he was Chief Legal Officer since 2018. Before Coinbase, Brooks was Executive Vice President, General Counsel, and Corporate Secretary of Fannie Mae. He also was a member of the senior executive management team of at OneWest Bank, N.A., as Vice Chairman and Chief Legal Officer.

© Michael Bacina. All rights reserved

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