News & Analysis as of

Special Purpose National Bank Charter

Troutman Pepper Locke

Georgia Grants Fiserv a Special Banking Charter: A Major Milestone for Fintech and Nonbank Direct Access to Card Networks

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In a significant development since our last post, Fiserv’s application for a merchant acquirer limited purpose bank (MALPB) charter has been approved by the Georgia Department of Banking and Finance. This approval marks a...more

Venable LLP

Georgia on the Mind: An Explainer for Payments Companies Considering the Merchant Acquirer Limited Purpose Bank Charter

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In January 2024, one of the largest U.S. non-bank merchant acquirers announced that it is pursuing a special-purpose bank charter developed by Georgia. Although the “merchant acquirer limited purpose bank” (MALPB) has been a...more

Ballard Spahr LLP

OCC approves national bank charter applications of fintech company

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The OCC announced this week that it has conditionally approved applications from Social Finance Inc. (SoFi) to create SoFi Bank, National Association (SoFi Bank, N.A.), as a full service national bank headquartered in...more

Ballard Spahr LLP

CSBS withdraws lawsuit seeking to block OCC approval of Figure Technologies charter application

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The Conference of State Bank Supervisors (CSBS) has withdrawn its lawsuit filed in D.C. federal district court in December 2020 seeking to block the OCC from granting a national bank charter to Figure Technologies Inc. The...more

Jones Day

OCC Victory Not a Clear Win for Fintech Charters

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On June 3, 2021, the Court of Appeals for the Second Circuit issued a decision in the OCC's appeal of the SDNY decision in Lacewell v. Office of the Comptroller of the Currency in which the NYDFS had successfully challenged...more

Troutman Pepper Locke

The Rise of Cryptocurrency for Banks

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On July 22, 2020, the Office of the Comptroller of the Currency (the OCC) confirmed in Interpretive Letter #1170 the authority of a national bank to provide cryptocurrency custody services. Since that time, the OCC has issued...more

Ballard Spahr LLP

Second Circuit orders dismissal for lack of standing of New York DFS lawsuit challenging OCC fintech charter

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The U.S. Court of Appeals for the Second Circuit has ruled that the lawsuit filed by the New York Department of Financial Services (DFS) seeking to block the OCC’s issuance of special purpose national bank (SPNB) charters to...more

Morrison & Foerster LLP

The Fintech Charter Lives To See Another Day: Second Circuit Reverses Anti-Fintech Charter District Court Ruling

The U.S. Court of Appeals for the Second Circuit revived the Office of the Comptroller of the Currency’s (OCC) controversial special-purpose national bank charter that had been challenged by the New York Department of...more

Nutter McClennen & Fish LLP

Nutter Bank Report: May 2021

Court Rules that Debt Collector Violated FDCPA with Communication to Dunning Vendor - A federal appellate court has recently ruled that a debt collector violated certain privacy requirements under the federal Fair Debt...more

Ballard Spahr LLP

OCC files to motion to dismiss CSBS lawsuit seeking to block OCC approval of Figure Technologies charter application

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The Office of the Comptroller of the Currency has filed a motion to dismiss the lawsuit filed by the Conference of State Bank Supervisors (CSBS) in D.C. federal district court seeking to block the OCC from granting a national...more

Eversheds Sutherland (US) LLP

Noteworthy developments in payments and fintech - March 2021

Industrial bank charters continue to gain momentum with approval of Square’s charter; payments and tech companies have become interested in industrial banks lately since the FDIC started approving them after a moratorium from...more

Ballard Spahr LLP

Second Circuit Hears Oral Argument In OCC Appeal From District Court Judgment In NYDFS Lawsuit Challenging Fintech Charter

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The U.S. Court of Appeals for the Second Circuit held oral argument last week in the OCC’s appeal from the district court’s final judgment in the lawsuit filed by the New York Department of Financial Services (DFS) seeking to...more

Ballard Spahr LLP

Conference of State Bank Supervisors files new lawsuit to block OCC approval of Figure Technologies charter application

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The Conference of State Bank Supervisors (CSBS) has filed a lawsuit in D.C. federal district court to block the OCC from granting a national bank charter to Figure Technologies Inc. According to the complaint, Figure,...more

Pillsbury Winthrop Shaw Pittman LLP

Financial Services Regulation in a Biden Administration: Personnel Is Policy

A closely divided Congress will limit financial services legislation but Biden appointees in key regulatory positions will have a large impact on the financial services policy agenda. The Biden administration is likely to...more

Ballard Spahr LLP

OCC files reply brief with Second Circuit in appeal from district court judgment in NYDFS lawsuit challenging fintech charter

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The OCC has filed its reply brief with the Second Circuit in its appeal from the district court’s final judgment in the lawsuit filed by the New York Department of Financial Services (DFS) challenging the OCC’s issuance of...more

Kilpatrick

Banking on the Business of Banking: How the 2nd Circuit's Ruling in Lacewell v. OCC Could Change the Future of Fintech Regulation

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Despite often operating on a nationwide scale, fintech companies rarely meet the stringent requirements for obtaining a national banking charter. Under the current regulatory landscape, these companies must therefore secure...more

Ballard Spahr LLP

OCC payments charter quickly generates industry concern

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As we reported, Acting Comptroller of the Currency Brian Brooks has previewed the OCC’s plans to introduce another special purpose national bank charter that would give payment companies a nationwide servicing platform and...more

Ballard Spahr LLP

NYDFS files brief with Second Circuit in OCC’s appeal from district court judgment in lawsuit challenging fintech charter

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The New York Department of Financial Services (DFS) has filed its opening brief with the Second Circuit in the OCC’s appeal from the district court’s final judgment in DFS’s lawsuit challenging the OCC’s issuance of special...more

McGuireWoods LLP

New York Files Brief in Support of Dismantling OCC’s Fintech Charter

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On July 23, 2020, the New York Department of Financial Services (“DFS”) filed its appellate brief asking the Second Circuit Court of Appeals to uphold the lower court’s decision to block the Office of Comptroller of the...more

Morgan Lewis - All Things FinReg

OCC Plans to Introduce Special Purpose National Bank Charter for Payments Companies

In a series of recent interviews (including with the American Bankers Association and a podcast with the ABA Banking Journal), Acting Comptroller of the Currency Brian Brooks discussed the Office of the Comptroller’s (OCC’s)...more

Ballard Spahr LLP

OCC Previews Plans To Introduce Special Purpose National Bank Charter For Payment Companies

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In recent interviews including a podcast with the ABA Banking Journal reported by Forbes, Acting Comptroller of the Currency Brian Brooks previewed the OCC’s plans to introduce another special purpose national bank charter...more

Ballard Spahr LLP

OCC files brief with Second Circuit in appeal from district court judgment in NYDFS lawsuit challenging fintech charter

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The OCC has filed its opening brief in its appeal to the Second Circuit from the district court’s final judgment in the lawsuit filed by the New York Department of Financial Services (DFS) seeking to block the OCC’s issuance...more

McGuireWoods LLP

Fintech Company Avoids Murky Regulatory Landscape by being the First U.S. Fintech Company to Acquire a Regulated Bank

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For the first time, a U.S. fintech company is acquiring a regulated U.S. bank, which will give it access to a stable and cheaper source of funding – as well as a national bank charter. On February 18th, LendingClub, one of...more

Ballard Spahr LLP

OCC appeals NY federal district court final judgment in NYDFS lawsuit challenging fintech charter

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The OCC has appealed to the Second Circuit from the district court’s final judgment entered in October 2019 in the lawsuit filed by the New York Department of Financial Services seeking to block the OCC’s issuance of special...more

Eversheds Sutherland (US) LLP

Southern District of New York rules against OCC fintech charter

On October 23, the District Court for the Southern District of New York (SDNY) issued a final judgment setting aside in relevant part the regulation on which the Office of the Comptroller of the Currency (OCC) based its...more

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