In the absence of modern charters and licenses, payments companies and other fintechs—both established financial services providers and new market entrants—must generally obtain 50+ money transmitter and possibly other state...more
The CFPB has approved a final rule that requires banks and certain other financial services providers to share a consumer’s personal financial data with another provider at the consumer’s request. The CFPB’s Personal...more
On July 25, 2024, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint statement to banks regarding risks...more
The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more
Everyone—including fintechs, other non-bank companies, and associated individuals—that either partners with banks or seeks to provide alternatives to insured deposits must comply with the FDIC's deposit insurance advertising...more
FDIC Announces Special Assessments to Recover Losses from Recent Bank Failures The FDIC has issued a proposed rule that would impose special assessments to recover the loss to the Deposit Insurance Fund (Fund) arising from...more
Here is the latest regarding the former Silicon Valley Bank of Santa Clara, California (“SVB”) and Signature Bank of New York, NY (“SB”) as of Monday, March 13, 2023 according to the FDIC and other regulators. We expect to...more
Headlines - ..FDIC Proposes Substantial Increase in Deposit Insurance Assessment Rates ..Federal Reserve Releases New CECL Implementation Tool: Expected Losses ..Estimator OCC Report Highlights Risks Facing the Federal...more
Federal Banking Agencies Issue CRA Modernization Proposal The federal banking agencies have jointly issued a proposed rule that would modernize their regulations that implement the Community Reinvestment Act (the “CRA”). The...more
In This Issue. The Federal Housing Finance Agency (FHFA) announced that Fannie Mae and Freddie Mac will no longer charge lenders the Adverse Market Refinance Fee; the Federal Deposit Insurance Corporation (FDIC) is seeking...more
On December 7, 2020, several bank and credit union trade associations (collectively, the “Associations”) submitted a joint letter (the “Letter”) to the Office of the Comptroller of the Currency (the “OCC”) opposing the...more
In the News. The Securities and Exchange Commission (SEC) adopted final rules to update and expand the statistical disclosures that bank and savings and loan registrants must provide to investors for the first time in 30...more
On October 27, 2017, the Office of the Comptroller of the Currency (OCC) issued a full-service national bank charter since the financial crisis to Winter Park National Bank. Winter Park National Bank is the first de novo...more
The fintech industry has justifiably greeted the OCC’s announcement of a national fintech charter with optimism. But one area where we have seen significant confusion is the possibility of the fintech charter being granted...more
Financial Industry Developments - OCC Discusses Marketplace Lending - On September 13, 2016, Comptroller of the Currency Thomas J. Curry discussed marketplace lending's risks and associated policy questions. He...more
Regulatory Developments - CFPB Responds to Industry Concerns on Know Before You Owe Rule - On April 28, the CFPB issued a letter to banking and industry groups in response to an inquiry by the Mortgage Bankers...more
The FDIC issued a notice of proposed rulemaking (the “Proposed Rule”) that would revise the FDIC’s risk-based deposit insurance assessment system to reflect the final Basel III capital rule (the “Final Capital Rule”) adopted...more