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Custody Battles: The FDIC's Latest Proposed Rule on FBO Accounts

The FDIC has issued a proposed rule that would apply to practically all bank-fintech arrangements that use custodial deposit accounts to provide customers with transactional features (also called "FBO" accounts for short)....more

Federal Banking Agencies Highlight Bank-Fintech Partnership Risks and Invite Comment

On July 25, 2024, the federal banking agencies issued a joint statement flagging potential risks in bank-fintech arrangements, along with a request for public information (RFI) on the benefits, risks, and risk management...more

Fintech Companies Might Need to Register with CFPB Under Proposed Rule

Last week, the Consumer Financial Protection Bureau (CFPB) proposed a rule to establish a public registry of terms and conditions in form contracts that purport to waive or limit consumer rights and protections. The rule...more

CFPB Proposes Nonbank Registry of Financial Law Violations; Potential for "Scarlet Letter"

The CFPB unveiled a far-reaching proposal to require certain nonbank financial firms to register with the CFPB on December 13, 2022, which is meant to enhance market monitoring and risk-based supervision efforts. The deadline...more

The CFPB Targets FinTechs and Other Nonbanks for Supervision and Examination

The Consumer Finance Protection Bureau ("CFPB") announced that it will examine nonbank financial companies that pose risks to consumers, using statutory authority that until now had gone unused. Additional examinations would...more

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