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Federal Reserve FinTech

Sheppard Mullin Richter & Hampton LLP

Fed Issues Cease and Desist Order for Crypto-Related Compliance and Risk Management Deficiencies

On September 4, the Federal Reserve Board (Fed) released enforcement actions against a Texas-based bank, addressing regulatory violations and compliance lapses. The Fed, joined by the Texas Department of Banking (TDB),...more

Venable LLP

Banking on a Nonbank Bank in 2024 - The ILC Option Revisited

Venable LLP on

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

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

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

Sheppard Mullin Richter & Hampton LLP

Federal Regulators Issue Joint Statement and Request for Information Emphasizing Caution with BaaS Model

On July 25, federal regulators issued a joint statement to further put banking organizations on notice of the inherent risks of collaborating with fintechs in offering deposit products and services. This guidance aims to...more

Ballard Spahr LLP

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

Ballard Spahr LLP on

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

Troutman Pepper

Federal Banking Agencies Reiterate Guidance on Managing Risks Posed By Fintech Partnerships and Other Third Party Relationships

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Last week, 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 highlighting...more

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 40: Financial Innovation and Supervision

RegFi co-hosts Jerry Buckley and Caroline Stapleton welcome podcast guest Tracy Basinger, former head of supervision at the Federal Reserve Bank of San Francisco and a senior advisor at the Klaros Group. Tracy brings a unique...more

Goodwin

10 Considerations for Fintechs Partnering with Community Banks

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As banking and technology become more integrated, banks are increasingly partnering with fintechs to expand their customer offerings. The rapid rise of these partnerships has generated questions for both banks and fintechs on...more

Sheppard Mullin Richter & Hampton LLP

Federal Reserve Board Issues Cease and Desist Order Against Banking-As-A-Service Provider

On June 14, the Federal Reserve Board (Fed) released a cease and desist order against an Arkansas-based banking-as-a-service (BaaS) provider for compliance and risk management failures. As part of the order, the bank is...more

Hudson Cook, LLP

CFPB Bites of the Month - May 2024 - CFPB: Light My Way, Virginia May

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In this month's article, we share some of our top "bites" covered during the May 2024 webinar....more

Ballard Spahr LLP

Federal Banking Agencies Issue Guide to Third-Party Risk Management Practices for Community Banks

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On May 3, 2024, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Office of the Comptroller of the Currency (“OCC”) jointly released the...more

Venable LLP

Fintechs, Novel Charters, and Fed Master Accounts - Of Elephants and Mouseholes

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A U.S. District Court recently rejected arguments that banks and institutions with novel charters have a statutory right to obtain a Federal Reserve master account. Master accounts let institutions access key parts of the...more

Orrick, Herrington & Sutcliffe LLP

Fed releases enforcement action against Wyoming-based bank holding company

On April 4, the Federal Reserve released an enforcement action against a Wyoming-based bank holding company as part of a September 2023 inspection that found alleged deficiencies related to the “fintech business strategy,...more

Goodwin

Payment Trends in 2024

Goodwin on

This edition of Fintech Flash identifies key issues we anticipate will impact the payments industry in 2024. First, the payments regulatory landscape continues to evolve, with a number of proposed rulemakings published by the...more

Nutter McClennen & Fish LLP

Nutter Bank Report: January 2024

OCC Requests Public Comments on Proposed Bank Merger Policy Statement and Rules The OCC has proposed a new policy to increase the transparency of the standards that the agency applies to review business combinations involving...more

Cadwalader, Wickersham & Taft LLP

Trends in 2024: American Bar Association Banking Law Committee Insights

From January 18th to 20th, the American Bar Association’s Banking Law Committee of the Business Law Section held its winter meeting in Washington, DC. This meeting not only provides an excellent retrospective of the previous...more

Orrick, Herrington & Sutcliffe LLP

NY Fed highlights an increase in unsecured loans from fintech firms in report, primarily among subprime lenders

On November 21, the Federal Reserve Bank of New York released a report on the rise and then contraction of unsecured personal loans from 2019 to 2023 for nonbank or fintech companies, and the role of alternative data and...more

Troutman Pepper

The Future of Payments: Exploring FedNow With the Payments Professor — Payments Pros – The Payments Law Podcast

Troutman Pepper on

In this episode of Payments Pros, Keith Barnett and Carlin McCrory are joined by Pidgin's Senior Vice President of Innovation Kevin Olsen to discuss faster payments and the FedNow service. Faster payments, such as real-time...more

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights: V 3, Issue 8, November 2023

FTC Amends Safeguards Rule to Require Non-Banking Financial Institutions to Report Data Security Breaches - “Amendment will require non-bank financial institutions to report when they discover that information affecting...more

Venable LLP

Fed Study Looks at Fintech-Issued Personal Loans and Role of Specialist Banks

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A study in the Finance and Economics Discussion Series (FEDS) by the Federal Reserve Board on consumer lending found that financial technology (FinTech) lenders are able to take advantage of federal preemptions from state...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - September 2023

Editor's Note 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...more

McGlinchey Stafford

Deep Dive into Payments: Q&A on Bank Partnership Considerations

McGlinchey Stafford on

But upon closer consideration, there is an interplay between a bank partner program and the Electronic Fund Transfer Act (EFTA) as implemented by Regulation E, particularly when it comes to timeframes for disputes, liable...more

Sheppard Mullin Richter & Hampton LLP

Federal Reserve Issues Guidance on Supervision of “Novel Activities” by Banks, Impacts Bank-Fintech Partnerships

The Federal Reserve Board recently issued two Supervision and Regulation Letters that provide guidance on the agency’s supervision of novel activities and the process such as fintech partnerships, crypto-related activities,...more

Morrison & Foerster LLP

Federal Reserve Issues Guidance on Novel Activities, Including Bank-Fintech Partnerships

On August 8, 2023, the Board of Governors of the Federal Reserve System (FRB) issued two Supervision and Regulation Letters (“SR Letters”) that provide guidance on the agency’s supervision of novel activities and the process...more

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