One of the beauties of the national banking system is that it allows state-chartered banks to offer uniform credit products across the 50 states without having to worry about state interest rate caps. This concept - rate...more
There have been a handful of recent marketplace lending developments that indicate that the legal uncertainties in the post-Madden world are not going away anytime soon....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
Proposed legislation to implement New York Governor Andrew Cuomo's 2018 Fiscal Year Executive Budget would amend the New York Licensed Lender Law to significantly extend its licensing requirements. The proposal threatens to...more