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Sheppard Mullin Richter & Hampton LLP

Fintech Industry Trade Associations Respond to Federal Regulators’ Joint RFI on Bank-Fintech Partnerships

On October 30, two leading fintech industry trade associations submitted comments (see comment letters here and here) in response to a joint Request for Information (RFI) issued by the Office of the Comptroller of the...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: Regulators Escalate Focus on the Risks of Bank Relationships with Fintechs and Other...

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On July 25, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a “Joint Statement on Banks’...more

Pillsbury - Global Sourcing Practice

U.S. Financial Regulators Continue Focus on Bank-Fintech Partnerships through Guidance and Request for Information

On July 25, 2024, the Board of Governors of the Federal Reserve System (FRB), Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) issued a joint statement describing potential...more

Alston & Bird

FDIC Proposes Rule to Revise Brokered Deposit Regulations and Issues Request for Information on Deposit Data

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In a proposed rule and information request, the Federal Deposit Insurance Corporation expressed its concerns with the current brokered deposit restrictions and reporting requirements. Our Financial Services Team zeroes in on...more

Cadwalader, Wickersham & Taft LLP

Banking Regulators’ Request for Information on Bank-Fintech Arrangements

On July 25, 2024, the Fed, the OCC and the FDIC (the “Banking Regulators”) released a “Request for Information on Bank-Fintech Arrangements Involving Banking Products and Services Distributed to Consumers and Businesses” (the...more

Venable LLP

FDIC Rethinks Brokered Deposits, Again

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The FDIC recently proposed a rule that would substantially change the 2020 final rule on brokered deposits that largely liberalized the FDIC’s framework. The proposed rule would eliminate many of the changes from 2020 and...more

Alston & Bird

Regulators Focus on Bank-Fintech Arrangements

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Through joint guidance and an information request, federal bank regulators underscored banks’ compliance responsibilities in their banking-as-a-service (BaaS) relationships with third parties. Our Financial Services Team...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - August 2024

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Morrison & Foerster LLP

Banking Agencies Address Banking Arrangements with Third Parties to Provide Deposit Products and Services

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

Ballard Spahr LLP

FDIC Seeking Comments on Including Uninsured Deposit Data on Call Reports

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The FDIC board on July 30 agreed to request information on deposit data that currently is not reported in the Federal Financial Institutions Examination Council’s Call Reports—including data on uninsured deposits....more

Ballard Spahr LLP

Bank Regulators Issue Statement on Third-Party Relationships with Financial Institutions and Publish Request for Information on...

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The federal banking regulators (The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation) issued on July 25 a lengthy joint statement...more

Mayer Brown

How Many Digits? FinCEN Seeks Comment on Bank Customer Identification Requirements

Mayer Brown on

On March 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), in consultation with the staffs of the federal banking agencies, issued a request for information and comment (the “RFI”)...more

Goodwin

OCC Solicits Research on Implications of Financial Technology for Banking

Goodwin on

Regulatory Developments - OCC Solicits Research on Implications of Financial Technology for Banking - On July 25, the OCC is seeking academic and policy-focused research on the impact that fintech and non-bank...more

Goodwin

SEC Proposes Rules to Include Certain Significant Market Participants as “Dealers” or “Government Securities Dealers”

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed rules to include certain significant market participants as “dealers” or “government securities dealers” to essentially eliminate the trader exclusion...more

Goodwin

OCC Reconsiders Controversial Revisions to CRA Rules

Goodwin on

In This Issue. The Office of the Comptroller of the Currency (OCC) announced that it will reconsider its controversial June 2020 final rule revising its Community Reinvestment Act (CRA) rules, and published its Semiannual...more

Goodwin

Financial Services Weekly Roundup: Madden Fix/Valid When Made Rule Faces New Challengers

Goodwin on

In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more

Ballard Spahr LLP

Financial Institution Regulators Address Financial Inclusion, Expansion of Access to Credit, and Further Consumer Protection from...

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Since early June 2020 when cries for racial justice resulted in a period of social unrest in the U.S., federal and state financial institution regulators have taken meaningful, proactive steps to acknowledge financial...more

Perkins Coie

Blockchain Week in Review - July 2020 #3

Perkins Coie on

US Developments - OCC Issues Interpretation that Banks Can Offer Crypto Custody Services - On July 22, 2020, the Office of the Comptroller of the Currency (OCC) issued an interpretive letter clarifying that national banks...more

Goodwin

Financial Services Weekly Roundup: The OCC’s True Lender Test Embraces A Simplified Solution

Goodwin on

In This Issue. The Office of the Comptroller of the Currency (OCC) proposed a rule that would establish that a national bank or federal savings association is the “true lender” of a loan if, as of the date of origination, the...more

Ballard Spahr LLP

FDIC Seeks Comment on Its Approaches to Rulemaking

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The Federal Deposit Insurance Corporation (the “FDIC”) has published a request for information in the Federal Register (the “RFI”) seeking comment on approaches it uses, or is considering using, to analyze the effects of its...more

Ballard Spahr LLP

Democratic Senators seek information about discrimination by lenders using algorithms

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Democratic Senators Elizabeth Warren and Doug Jones have sent a letter to the CFPB, Federal Reserve, OCC, and FDIC expressing concern that fintech and traditional lenders using algorithms in their underwriting processes are...more

Manatt, Phelps & Phillips, LLP

Small-Dollar Lending: State AGs Offer FDIC Advice, CA DBO Takes Action

Small-dollar lending made headlines recently, with a group of 14 attorneys general responding to the Federal Deposit Insurance Corporation’s (FDIC) request for information (RFI) on the subject and a new California Department...more

Ballard Spahr LLP

State AGs submit comments to FDIC on small-dollar lending

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A group of 13 state attorneys general and the District of Columbia AG have sent a letter to the FDIC commenting on the agency’s request for information on small-dollar lending. ...more

Goodwin

Financial Services Weekly News - March 2018 #2

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Editor's Note - Judge Rules for Defendants in Mutual Fund Excessive Fee Lawsuit. On March 9, the U.S. District Court for the Southern District of Ohio entered summary judgment for defendants in an action brought under...more

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