Navigating Regulatory Waters: Recent Enforcement Actions in BaaS — Payments Pros – The Payments Law Podcast
Consumer Finance Monitor Podcast Episode: Have State-Chartered, FDIC-Insured Banks Finally Achieved Interstate Usury Parity with National Banks?
Consumer Finance Monitor Podcast Episode: Regulators Escalate Focus on the Risks of Bank Relationships with Fintechs and Other Third Parties
2024 State Legislative Review: Key Payment Laws and Their Impacts — Payments Pros – The Payments Law Podcast
First Republic Executives Fail in Attempt to Recover Nonqualified Deferred Compensation Plan Assets
The Future of Bank-Fintech Partnerships and Banking as a Service — The Consumer Finance Podcast
In That Case: Cantero v. Bank of America
Navigating Bank-Fintech Partnerships: Avoiding Common Pitfalls — The Consumer Finance Podcast
Revisiting Financial Institution Incentive Compensation Rules Under Dodd-Frank — The Consumer Finance Podcast
Redlining Complications Caused by Implementation of 2020 Census Tracts
U.S. District Court Addresses Federal Preemption for State Credit Reporting Laws
How to estimate how your performance will look under the new CRA
Instant Decline, Instant Relief? Unpacking the CFPB's Proposed Rule on NSF Fees — Payments Pros: The Payments Law Podcast
Fintech Focus Podcast | Are Regulators Dictating Fintech Deal Terms?
The Coming Perfect Storm
2023 Payments Year in Review: CFPB and FTC Regulatory Trends — Payments Pros – The Payments Law Podcast
Year in Review and a Look Ahead: Fintech Developments — The Consumer Finance Podcast
The CFPB Targets Data Brokers with Latest Proposed Rule
State Laws on Screening and Federal Preemption – Where Are We Now and Where Are We Heading? — FCRA Focus Podcast
Redefining Banking: A Conversation on the CFPB's Proposed 1033 Rule — Payments Pros: The Payments Law Podcast
The banking regulators have not yet gone out on vacation, as demonstrated by this grab-bag of announcements, speeches, rules and guidance: Acting Comptroller of the Office of the Comptroller of the Currency (OCC),...more
On September 18, 2023, the U.S. Basel III Endgame proposal was published in the Federal Register. The comment period ended on January 16, 2024, with the banking regulators (the Federal Reserve, the OCC, and the FDIC) having...more
It is no secret that the Federal Reserve, the FDIC, and the OCC have zeroed in on banks' use of third parties for products, services, and other operations, the risks those arrangements may pose, and banks' responsibility to...more
On March 30, the OCC announced the establishment of the Office of Financial Technology, and selected Prashant Bhardwaj to lead the office as Deputy Comptroller and Chief Financial Technology Officer beginning April 10...more
Our Blockchain & Digital Assets Team offers a snapshot sample of significant recent developments by a panoply of federal agencies and departments that represent the expanding array of enforcement tools used by federal...more
I. Introduction - As we note in our companion memorandum, the Office of the Comptroller of the Currency (“OCC”) continues along its cautious course of allowing fintech and digital asset firms into the so-called...more
In response to increasingly frequent and sophisticated cybersecurity attacks on banks and bank service providers, the federal prudential banking regulators—the Office of the Comptroller of the Currency (OCC), the Board of...more
Building on his remarks to the Blockchain Association and the American Fintech Council earlier this month, the Acting Comptroller of the Currency, Michael J. Hsu, issued a statement on November 16 before the Federal Reserve...more
It has been a period rife with notable shifts on the global stage; a new administration in the US, the end of the Brexit transition period and the reaching of key milestones in the discontinuation of LIBOR, to name but a few....more
On July 13, the Federal Reserve, FDIC, and OCC proposed risk management guidance to help banking organizations manage risks related to third-party relationships, including relationships with vendors, FinTech companies,...more
On July 9, 2021, President Biden signed the wide-ranging Executive Order on Promoting Competition in the American Economy, aimed at increasing competition in all sectors of the American economy, including banking and consumer...more
Crisis has set the stage for fintech companies in 2021, creating both new opportunities and potentially unprecedented challenges to innovation. While the coronavirus pandemic continues to accelerate the digital transformation...more
The OCC issued a letter last week stating that “a national bank [and a federal savings association] may provide . . . cryptocurrency custody services on behalf of customers, including by holding the unique cryptographic keys...more
The New York Department of Financial Services was told by a federal court in New York that it could proceed with its lawsuit challenging plans of the Office of the Comptroller of the Currency to accept and consider...more
On October 31, 2018, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Office of the Comptroller of the Currency (the “OCC”) and the Federal Deposit Insurance Corporation (the “FDIC”) issued a...more
In a press release, the organizers of Varo Bank, N.A. announced they have been granted preliminary approval by the OCC of their application to form a de novo national bank, which they claim “put[s] Varo on track to become the...more
On July 31, 2018 the Office of the Comptroller of the Currency (OCC) announced that, effective immediately, it is now accepting national bank charter applications from nondepository financial technology (fintech) companies...more
The Office of the Comptroller of the Currency announced, in a highly anticipated decision, that it would begin to consider special-purpose charter applications from fintech entities. This move, which has been the subject of...more
The Comptroller of the Currency (“OCC”) presented a White Paper in December 2016 on Exploring Special Purpose National Bank Charters for Fintech Companies (“White Paper”). Comptroller Tom Curry noted that he had asked the OCC...more
A New York federal district court has dismissed the lawsuit filed by the New York Department of Financial Services (DFS) challenging the OCC’s authority to grant special purpose national bank (SPNB) charters to nondepository...more
In remarks last week at Georgetown University’s Institute of International Economic Law’s Fintech Week event, Acting OCC Comptroller Keith Noreika provided the “latest on our thinking regarding a charter for fintech companies...more
The Conference of State Bank Supervisors has released a list of 33 companies that will serve as members of its Fintech Industry Advisory Panel. According to the CSBS, the Advisory Panel’s purpose is “to support state...more
On September 25, the Acting Comptroller of the Currency and leading participants in the online lending industry gathered in Washington, D.C. at the second annual Online Lending Policy Institute (OLPI) Online Lending Policy...more
Regulation and innovation is not a zero sum-game – that is what a Senior Advisor to the Chair of the Securities and Exchange Commission (the “SEC”) said at the Financial Industry Regulatory Authority’s (“FINRA”) inaugural...more
The Office of the Comptroller of the Currency (OCC) has filed a motion to dismiss the lawsuit filed by the New York Department of Financial Services (DFS) challenging the OCC’s authority to grant special purpose national bank...more