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The US Securities and Exchange Commission and crypto exchange Gemini have asked to pause the regulator’s suit over the exchange's Gemini Earn program, saying they want to discuss a potential resolution. 

In an April 1 letter to New York federal court judge Edgardo Ramos, lawyers representing the SEC and Genesis requested a 60-day hold on the case and that all deadlines be pulled “to allow the parties to explore a potential resolution.” 

“In this case, the parties submit that it is in each of their interests to stay this matter while they consider a potential resolution and agree that no party or non-party would be prejudiced by a stay,” the letter states.

The lawyers added that a stay was in the court’s interest as “a resolution would conserve judicial resources” and proposed that a joint status report be submitted within 60 days after the entry of the stay.

The SEC sued Gemini and crypto lending firm Genesis Global Capital in January 2023, alleging they offered unregistered securities through the Gemini Earn program.

Two Republicans who received a combined $1.5 million from the crypto-backed political action committee (PAC) Fairshake will enter the US House after winning special elections in Florida.

Republican Jimmy Patronis won the vacant seat in Florida’s 1st Congressional District to replace Matt Gaetz, taking 57% of the vote to defeat Democrat Gay Valimont, according to AP News data.

Randy Fine also took Florida’s 6th Congressional District with 56.7% of the vote to beat his Democratic rival, public school teacher Josh Weil, and fill a seat left vacant by Mike Waltz, who took a job as White House national security adviser.

Florida’s 1st and 6th Congressional Districts — located in Florida’s western panhandle and along the state’s northeast coast — have been controlled by Republicans for roughly 30 years, but their lead has narrowed in recent years.

Fairshake, a PAC backed by crypto industry giants including Coinbase, Ripple and Andreessen Horowitz, gave Fine around $1.16 million in advertising spending and funneled $347,000 to Patronis to support his campaign.

Several British trade associations have asked Prime Minister Keir Starmer’s office to appoint a special envoy dedicated to crypto and for a dedicated action plan for digital assets and blockchain technology.

In a March 31 letter, the coalition of six UK digital economy trade bodies urged Starmer’s special adviser on business and investment, Varun Chandra, for a “greater strategic focus and alignment to deliver investment, growth and jobs” for the crypto industry. 

The group, which consisted of the UK Cryptoasset Business Council, Global Digital Finance, The Payments Association, Digital Currencies Governance Group, the Crypto Council for Innovation and techUK, noted the US policy shift on crypto under President Donald Trump and his appointment of a crypto czar.

Britain’s commitment to an economic trade deal focused on technological cooperation with the US “presents a significant opportunity to mirror the United States’ ambition in fostering leadership in blockchain, digital assets, and other emerging financial technologies,” the letter stated. 

The group recommended that the UK appoint a blockchain special envoy, similar to the US, to coordinate policy, foster innovation, and position the country competitively in global markets.

Fraudulent tech workers with ties to North Korea are expanding their infiltration operations to blockchain firms outside the US after increased scrutiny from authorities, with some having worked their way into UK crypto projects, Google says.

Google Threat Intelligence Group (GTIG) adviser Jamie Collier said in an April 2 report that while the US is still a key target, increased awareness and right-to-work verification challenges have forced North Korean IT workers to find roles at non-US companies.

“In response to heightened awareness of the threat within the United States, they’ve established a global ecosystem of fraudulent personas to enhance operational agility,” Collier said. 

“Coupled with the discovery of facilitators in the UK, this suggests the rapid formation of a global infrastructure and support network that empowers their continued operations,” he added. 

Google's Threat Intelligence Group says North Korea's tech workers expanded their reach amid a US crackdown. Source: Google

Kentucky’s finance watchdog has dismissed its lawsuit against Coinbase over the exchange’s staking rewards program, following its peers in Vermont and South Carolina.

Kentucky’s Department of Financial Institutions filed the stipulation to dismiss jointly with Coinbase on April 1, ending the state’s legal action against the exchange first filed along with 10 other state regulators in June 2023.

Coinbase chief legal officer Paul Grewal posted to X on April 1, calling for Congress “to end this litigation-driven, state-by-state approach with a federal market structure law.”

Source: Paul Grewal

Financial regulators from 10 states launched similar suits against Coinbase in June 2023, on the same day the Securities and Exchange Commission sued the exchange — a lawsuit the SEC dropped last month.

Despite Bitcoin’s 2.2% gains on April 1, BTC (BTC) hasn’t traded above $89,000 since March 7. Even though the recent price weakness is often linked to the escalating US-led global trade war, several factors had already been weighing on investor sentiment long before President Donald Trump announced the tariffs.

Some market participants claimed that Strategy’s $5.25 billion worth of Bitcoin purchases since February is the primary reason BTC has held above the $80,000 support. But, regardless of who has been buying, the reality is that Bitcoin was already showing limited upside before President Trump announced the 10% Chinese import tariffs on Jan. 21.

Gold/USD (left) vs. Bitcoin/USD (right). Source: TradingView / Cointelegraph

The S&P 500 index hit an all-time high on Feb. 19, exactly 30 days after the trade war began, while Bitcoin had repeatedly failed to hold above $100,000 for the previous three months. Although the trade war certainly affected investor risk appetite, strong evidence suggests Bitcoin's price weakness started well before President Trump took office on Jan. 20.

Spot Bitcoin ETFs inflows, strategic Bitcoin reserve expectations and inflationary trends

Another data point that weakens the relation with tariffs is the spot Bitcoin exchange-traded funds (ETFs), which saw $2.75 billion in net inflows during the three weeks following Jan. 21. By Feb. 18, the US had announced plans to impose tariffs on imports from Canada and Mexico, while the European Union and China had already retaliated. In essence, institutional demand for Bitcoin persisted even as the trade war escalated.

Crypto exchange Backpack has initiated the first phase of the claims process for former FTX users in Europe.

According to an April 1 announcement, users will need to create an account on the exchange, submit Know Your Customer information, and connect it to their FTX EU claim account.

Backpack has not set a deadline for this phase of the claims process and has yet to provide a timeline for when distributions will begin. Users will face a withdrawal fee of €5 ($5.39) for claims under €2,000 ($2,158) and 0.25% for amounts above it.

Source: Armani Ferrante

Backpack acquired FTX EU in January 2025 to offer crypto derivatives, including perpetual futures, throughout Europe. The acquisition marked the end of a lengthy battle to buy the European arm of the bankrupt exchange.

Texas Senator Ted Cruz proposed a bill aimed at incentivizing crypto miners to use flared gas for energy generation in the state.

In an April 1 notice, Cruz said he had introduced the Facilitate Lower Atmospheric Released Emissions, or FLARE, Act in the US Senate, aiming to make Texas “the number one place for Bitcoin mining.” Mining advocacy group Digital Power Network supported the bill, and Bitcoin (BTC) miner MARA Holdings endorsed the proposed legislation on X, claiming it would reduce emissions and “unlock stranded energy.”

April 1 draft of FLARE Act. Source: Ted Cruz

According to the text of the bill, the FLARE Act proposed amending the US Internal Revenue Code to incentivize market participants — including digital asset miners — to “capture gas that would otherwise be flared or vented and to use such gas in value-added products.” If signed into law, the legislation would take effect on properties put into service starting in 2026.

Related: Bitcoin mining using coal energy down 43% since 2011 — Report

Stablecoin issuer Circle Internet Group has filed an S-1 registration statement for an initial public offering in the US, an April 1 filing with the Securities and Exchange Commission shows.

The USD Coin (USDC) issuer is planning to list its Class A common stock on the New York Stock Exchange under the symbol “CRCL,” the filing shows.

Circle’s prospectus does not detail the number of shares to be offered or what the IPO target price will be.

The IPO filing also showed that Circle brought in $1.67 billion in revenue for 2024 — marking a 16% year-on-year increase — while its EBIDTA (Earnings before Interest, Tax, Depreciation, and Amortization) fell 29% to $284.8 million.

Circle’s financials over the last three years ended Dec. 31. Source: SEC

This is a developing story, and further information will be added as it becomes available.

American Bitcoin Corp., a Trump family-backed crypto mining operation, has plans to raise additional capital, including through an initial public offering (IPO), according to an April 1 report by Bloomberg. 

On March 31, Hut 8 — a publicly traded Bitcoin (BTC) miner — acquired a majority stake in American Bitcoin (formerly American Data Centers), whose founders include Donald Trump Jr. and Eric Trump. 

After the deal announcement, Hut 8 transferred its Bitcoin mining equipment into the newly created entity, which is not yet publicly traded. 

While American Bitcoin will focus on crypto mining, Hut 8 plans to target data center infrastructure for use cases such as high-performance computing. The deal “evolves Hut 8 toward more predictable, financeable, lower-cost-of-capital segments,” Asher Genoot, CEO of Hut 8, said in a statement.

“So you can see this in the long term as two sister publicly traded companies,” Genoot told Bloomberg. “One that is energy, infrastructure data centers and the other one that’s Bitcoin, AISCs and reserves and together they form a vertically integrated company that has some of the best economics out there.”

The Ethereum network’s main source of income from layer-2 (L2) scaling chains — “blob fees” — has sunk to the lowest weekly levels so far this year, according to data from Etherscan. 

In the week ending March 30, Ethereum earned only 3.18 Ether (ETH) from blob fees, according to Etherscan, or approximately $6,000 US dollars as of April 1. 

This figure marks a 73% drop from the prior week and a more than 95% decline from the week ending March 16, when Ethereum’s income from blob fees exceeded 84 ETH, Etherscan said in an X post. 

Source: Etherscan

Related: Ethereum fees poised for rebound amid L2, blob uptick

APX Lending, a crypto-backed loan company, has gained exemptive relief from the Canadian Securities Administration (CSA) to offer crypto-backed loans without requiring traditional dealer registration or prospectus filings.

“Over the last 2 years, APX developed a […] regulatory framework in collaboration with the Ontario Securities Commission (OSC) to facilitate this, as no such framework previously existed in Canada,” a spokesperson for APX told Cointelegraph. “This exemption is specific to APX and does not establish a precedent for other companies.”

The platform currently supports Bitcoin (BTC) and Ether (ETH) as backing collateral for loans in Canadian or US dollars. APX plans to add more digital assets and fiat currencies options in the near future.

The company claims to be expanding its reach to the United States, with future expansions planned for Australia and New Zealand pending regulatory approval. Andrei Poliakov, founder and CEO of APX Lending, said in a statement:

“By engaging with Canadian regulators and leading the way in Canada, we are setting a new benchmark for compliance and security in crypto-backed lending, helping retail and institutional borrowers unlock liquidity while maintaining ownership of their digital assets."

APX loans range from 20%-60% loan-to-value (LTV), with an automated liquidation mechanism triggered at 90% if no corrective action is taken by the borrower to top up collateral or partially repay the loan when LTV reaches the 80% warning level and they are notified of the potential liquidation.

Kristin Smith, CEO of the US-based Blockchain Association, will be leaving the cryptocurrency advocacy group for the recently launched Solana Policy Institute.

In an April 1 notice, the Blockchain Association (BA) said Smith would be stepping down from her role as CEO on May 16. According to the association, the soon-to-be former CEO will become president of the Solana Policy Institute on May 19.

The association’s notice did not provide an apparent reason for the move to the Solana advocacy organization nor say who would lead the group after Smith’s departure. Cointelegraph reached out to the Blockchain Association for comment but did not receive a response at the time of publication.

Blockchain Association CEO Kristin Smith’s April 1 announcement. Source: LinkedIn

Smith, who has worked at the BA since 2018 and was deputy chief of staff for former Montana Representative Denny Rehberg, will follow DeFi Education Fund CEO Miller Whitehouse-Levine, leaving his position to join the Solana Policy Institute as CEO. According to Whitehouse-Levine, the organization plans to educate US policymakers on Solana.

Ethereum’s native token, Ether (ETH), registered four consecutive red monthly candles after the altcoin dropped 18.47% in March. The altcoin’s current market structure reflects a sustained bearish trend not seen since the bear market of 2022.

With each monthly close taking place below the previous month’s low, analysts are beginning the debate about whether ETH is approaching a bottom or if there is more downside ahead for the altcoin.

Ethereum/Bitcoin ratio hits new 5-year low

On March 30, the Ethereum/Bitcoin ratio dropped to a five-year low of 0.021. The ETH/BTC ratio measures ETH’s value against Bitcoin (BTC), and the current decline underlines Ether’s underperformance against Bitcoin over the past five years.

In fact, the last time the ETH/BTC ratio dipped to 0.021, ETH was valued between $150-$300 in May 2020.

Ethereum/Bitcoin 1-month chart. Source: Cointelegraph/TradingView

GoMining, a platform that allows users to mine Bitcoin (BTC) through data centers, is launching a $100 million Bitcoin mining fund for institutional investors. Custodied by Bitgo, the fund promises annual distributions from mining yield and a strategy that focuses on Bitcoin rewards and reinvestment.

GoMining’s Alpha Blocks Fund comes as more companies have added Bitcoin to their balance sheets, capturing enthusiasm surrounding the resurgence of the world’s top cryptocurrency by market capitalization. Companies that have done so, including Japan’s Metaplanet and medical technology company Semler Scientific, have seen their stock prices increase.

“Unlike passive equity investments, the Alpha Blocks Fund offers direct exposure to mined Bitcoin via a fully managed, compounding hashrate strategy,” a GoMining spokesperson told Cointelegraph.

“BTC rewards are reinvested to increase the fund’s hashrate and improve miner efficiency — creating real, yield-driven outcomes. Our model is built for performance, not market sentiment, and integrates utility-based advantages that listed mining companies typically don’t offer.”

According to a press release shared with Cointelegraph, GoMining Institutional operates with 7.3 Exahash of active hash power.

For the second time, Alabama Senator Tommy Tuberville is set to reintroduce a bill aimed at allowing Americans to add cryptocurrency to their retirement savings plans.

In a March 31 Fox News interview, Tuberville said he planned to reintroduce his “Financial Freedoms Act” legislation after two failed attempts to get the legislation through Congress in 2022 and 2023. In announcing the bill, the Alabama senator said he wanted to help US President Donald Trump’s perceived role as a “crypto president.” 

“Give people a chance to breathe for once [...] let them do what they do best [which] is invest their money,” said the senator. 

The Financial Freedom Act, which Tuberville first introduced in the US Senate in May 2022, proposed scaling back regulations with the Department of Labor over the types of investments used in 401(k) retirement plan fiduciaries. The senator said he would reintroduce the bill on April 1, but congressional records showed no movement at the time of publication.

Related: Trump-linked crypto ventures may complicate US stablecoin policy

Asset manager Grayscale has filed to list an exchange-traded fund (ETF) holding a diverse basket of spot cryptocurrencies, US regulatory filings show.

On April 1, Grayscale submitted an S-3 regulatory filing to the US Securities and Exchange Commission (SEC), which is required to convert the non-listed fund to an ETF. 

The Grayscale Digital Large Cap Fund, which was created in 2018 but is not yet exchange-traded, holds a crypto index portfolio comprising Bitcoin (BTC), Ether (ETH), Solana (SOL), XRP (XRP) and Cardano (ADA). 

As of April 1, the fund has more than $600 million in assets under management (AUM) and is only available to accredited investors (entities or individuals with high net worth), according to Grayscale’s website.

The filing follows an Oct. 29 request by NYSE Arca, a US securities exchange, for permission to list the Grayscale index fund. 

Bitcoin (BTC) repeated earlier volatility at the April 1 Wall Street open as US trade tariff talk kept markets nervous.

BTC/USD 1-hour chart. Source: Cointelegraph/TradingView

Bitcoin stays erratic ahead of crunch tariffs

Data from Cointelegraph Markets Pro and TradingView showed BTC/USD making rapid moves within its weekly trading range of around $83,000.

US stocks ticked lower at the open, while gold came off fresh all-time highs of $3,149 per ounce.

Talk of recession began to return to the spotlight ahead of US President Donald Trump’s so-called “Liberation Day,” due on April 2 and on which he promised to unveil a new round of trade tariffs.

A number of altcoins and memecoins saw a sharp sell-off on April Fools’ Day, April 1, with some tokens, including Act I The AI Prophecy, dropping nearly 60% in minutes.

Act I The AI Prophecy (ACT), a token associated with the eponymous project focused on artificial intelligence, plunged 58% from $0.19 to $0.08 in less than an hour on April 1, with its market cap shedding $96 million, according to data from CoinMarketCap.

The sharp drop of ACT came along with notable red action in the altcoin market, with memecoins like sudeng (HIPPO), CZ’S Dog (BROCCOLI), Kishu Inu (KISHU), DeXe (DEXE), dForce (DF) and more seeing significant price declines.

Cryptocurrency market at a glance. Source: Coin360

The broader crypto market hasn’t reacted negatively to panic in altcoin markets, with major cryptocurrencies like Bitcoin (BTC) remaining green at the time of writing.

Opinion by: Dr. Michael Tabone, senior economist for Cointelegraph

Bitcoin (BTC) has long been hailed as unbreakable and untouchable, a digital stronghold against the forces of change. Bitcoin’s bedrock of security is facing its first true test with quantum computing, which should be addressed sooner rather than later. Its cryptographic armor will crack if not addressed, forcing the network to adapt or perish.

Bitcoin’s node count is growing, but incentives are still absent

Bitcoin’s full node network has grown over time, a sign of increasing adoption and a more robust infrastructure, but the core issue remains. The voluntary act of running a node still has no financial incentive. Miners earn rewards for securing the network, yet full node operators get nothing for their role in keeping Bitcoin decentralized.

At the same time, a significant portion of these nodes are run by exchanges, custodians and large mining pools. These are centralized entities with financial incentives to maintain control. Suppose Bitcoin’s node network continues to expand without proper incentives. In that case, the risk remains that validation will become increasingly dependent on a few well-funded players rather than a truly distributed base of individual users (see Figure 1).

FBitcoin node operation has increased by only 15,605 in 8 years. Source: Bitnodes.io 

Cryptocurrency exchange Bybit has announced the shutdown of its non-fungible token (NFT) marketplace.

In an April 1 announcement, Bybit warned its users that its NFT marketplace will cease operations on April 8, 2025, at 4:00 pm (UTC). Furthermore, at that time, the exchange will also shut down its Inscription Marketplace and its initial decentralized exchange offering initiative.

The announcement explains that the measures are part of Bybit’s “efforts to streamline our offerings.” The decision follows a similar decision by major NFT marketplace X2Y2 announced earlier this week.

Charu Sethi, president at NFT-focused Polkadot and Kusama chain Unique Network, told Cointelegraph at the time that the market moved on from speculative to utility-based:

“The speculative phase focused on collectibles and trading is over, but NFTs are now entering their next growth era as core infrastructure enabling massive opportunities in gaming, AI, fan engagement and content authentication.“

The NFT market is on a downward trend

The non-fungible token market at large is seeing a significant downturn. Daily NFT trading volume was over $18 million 364 days ago and stands at $5.34 million at the time of publication — a 70% fall.

Publicly traded US-based crypto exchange Coinbase saw its worst quarter since the collapse of crypto exchange FTX in 2022.

Coinbase shares started 2025 trading at just over $257 on Jan. 2 and ended the quarter at a little over $172 on March 31, a dip of 33%, according to market data.

This makes the first quarter of 2025 the worst for Coinbase’s stock performance since the collapse of FTX in November 2022. In Q4 of that year, its share price went from nearly $66 on Oct. 3 to $35.4 on Dec. 30, a loss of 46.4%.

Coinbase shares year-to-date price chart. Source: Google Finance

Coinbase has gained a significant foothold in the crypto market. Its prevalence is substantial enough that some industry experts recently told Cointelegraph its emergence as the Ethereum network’s largest node operator raises concerns about network centralization.

Update April 1, 1:42 pm UTC: This article has been updated to add comments from Cyvers co-founder and chief technology officer Meir Dolev.

An unauthorized party withdrew about $70 million in digital assets from open-source payment platform UPCX, according to a security alert issued on April 1.

The blockchain security firm Cyvers flagged suspicious activity involving 18.4 million UPC tokens, estimating the value of the compromised funds at $70 million.

Cyvers said someone accessed a UPCX address and upgraded its ProxyAdmin contract. The attacker then executed a function that allows admins to withdraw, leading to fund transfers from three different management accounts. 

At the time of writing, the stolen tokens had not been swapped for other crypto assets.

Key takeaways

Smart money consists of institutional investors with advanced tools and knowledge that can influence crypto market trends.

Key concepts like order blocks, liquidity zones and fair value gaps can help traders align with smart money strategies.

Real-time tracking tools such as Glassnode, Nansen and CoinGecko allow traders to follow smart money’s moves and capitalize on them.

Following the movements of smart money is akin to navigating the open sea, using its wake to position yourself for success in the crypto market.

Smart money refers to the money being invested by individuals or organizations that know the markets inside and out. We’re talking about institutional investors, hedge funds and well-seasoned traders. These are the big players who have access to more information and tools than most of us, and they use that knowledge to make strategic decisions.

A former executive of the Web3 game Blade of God X (BOGX) accused the project of abandoning its blockchain-based roadmap after raising funds through the crypto space.

On April 1, BOGX’s former chief marketing officer Amber Bella claimed in an X post that despite being funded by Web3 sources, the game “completely abandoned” its Web3 goals and the team working on its Web3 features.  

“Web3 was completely abandoned, and my Web3 team’s salaries went from delayed payments to no payments at all,” Bella claimed.

The former game executive also said that instead of compensating users and repaying funds to non-fungible token (NFT) buyers, the game’s founder, Tnise Liu Yang, decided to block her from all personal communication channels.

Related: Kalshi sues Nevada and New Jersey gaming regulators

The use of hydrocarbon fuels in Bitcoin mining has seen a sharp decline over the past 13 years, with the use of coal energy dropping significantly.

The share of coal energy use in Bitcoin (BTC) mining has dropped from 63% in 2011 to 20% in 2024, according to a new report released by the industry organization MiCA Crypto Alliance in collaboration with the risk metrics data platform Nodiens.

In parallel, the share of renewable energy used in Bitcoin mining has steadily increased, growing at an average rate of 5.8% per year.

Bitcoin absolute energy consumption trends and share of renewable and coal energy. Source: MiCA Crypto Alliance

The data reflects a steady shift of Bitcoin mining to cleaner and more sustainable energy solutions, with the study forecasting further decarbonization and mitigation of BTC’s environmental footprint in the coming years.

Japan-based Metaplanet has expanded its Bitcoin holdings, purchasing 696 BTC for 10.2 billion yen ($67 million), the company announced in an April 1 post on X.

The investment lifts Metaplanet’s total Bitcoin stash to 4,046 BTC, valued at over $341 million at the time of writing.

Source: Metaplanet

Stock split targets investor accessibility

The acquisition comes shortly after Metaplanet issued 2 billion Japanese yen ($13.3 million) of bonds to buy more BTC, Cointelegraph reported on March 31.

Source: Simon Gerovich

Tether, issuer of the USDT stablecoin, acquired 8,888 Bitcoin in the first quarter of 2025, according to onchain data.

Onchain transaction data shows that Tether moved its newly acquired Bitcoin (BTC), worth roughly $750 million at the time of writing, from a Bitfinex address to a wallet it controls. Data provided by onchain analytics platform Arkham Intelligence shows that the firm currently holds 100,521 BTC, worth about $8.46 billion.

Tether’s Bitcoin balance chart. Source: Arkham Intelligence

The news follows mid-February reports that Tether could be forced to sell part of its Bitcoin holdings to comply with proposed US regulations. JP Morgan wrote in a report that potential stablecoin regulation could consider a significant portion of the firm’s current reserve as non-compliant:

“Under the proposed bills, Tether would have to implicitly replace its non-compliant assets with compliant assets. […] This would imply sales of their non-compliant assets (such as precious metals, Bitcoin, corporate paper, secured loans.”

Still, Tether argued against the conclusion of the JP Morgan analyst. A Tether spokesperson criticized the analysts in correspondence sent to Cointelegraph, saying “they understand neither Bitcoin nor Tether” and highlighting that the US stablecoin laws have yet to be finalized.

A US dollar-pegged stablecoin launched by a cryptocurrency platform tied to US President Donald Trump’s family could complicate ongoing bipartisan efforts to pass stablecoin legislation in Congress, raising concerns about potential conflicts of interest.

The Trump-linked World Liberty Financial (WLFI) crypto platform launched the World Liberty Financial USD (USD1) US dollar-pegged stablecoin in early March, prompting concerns over potential conflicts of interest.

Despite political pushback from Democratic Party lawmakers, WLFI’s stablecoin plans are in line with the current US stablecoin legislation, according to Anastasija Plotnikova, co-founder and CEO of blockchain regulatory firm Fideum.

“The planned backing, audits, qualified custody, public blockchains and no native yield-bearing — all these elements are well in line with the GENIUS and STABLE acts,” she said in an interview with Cointelegraph.

“I would argue that this is a direct expression of support to the US-based stablecoins, and in any case, the stablecoin issuer is subject to the authorization of OCC, state regulators and the Board of Governors of the Federal Reserve,” she added.