Becoming or owning an industrial loan company (or ILC)—the elusive "nonbank bank" option, as Congress coined the term in 1987— still has an allure for financial services providers that want to (1) lend on a national scale...more
An industrial bank or industrial loan company (each, an ILC) charter can be an attractive option for a financial technology company (fintech) or other company seeking to enter the banking space. In June 2024, the Federal...more
On March 9, a three-judge panel of the Second Circuit heard oral argument on the question of whether the OCC can legally issue national bank charters to non-depository financial technology (fintech) firms. The case is...more
In previous posts in our BankBCLP.com series on this topic, we’ve attempted to define “open banking” and the ways in which it is attracting increasing industry attention through open APIs. As our series continues, we describe...more
On October 25, 2018, the Conference of State Bank Supervisors (CSBS) filed suit in the U.S. District Court for the District of Columbia challenging the Office of the Comptroller of the Currency’s (OCC) creation of a new...more
On April 30, 2018, the United States District Court for the District of Columbia dismissed a lawsuit filed one year earlier by the Conference of State Bank Supervisors (CSBS) disputing the authority of the Office of the...more
NYSDFS Superintendent Maria T. Vullo submitted a comment letter opposing the OCC’s proposal to create a new national bank charter for FinTech companies. Vullo noted that a one-size-fits-all federal charter will not work to...more