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FDIC Responds To Choke Point Scrutiny With Clarified TPPP Guidance

On July 28, the FDIC issued FIL-41-2014 to clarify its supervisory approach to bank relationships with third-party payment processors (TPPPs). In short, the letter removes the FDIC’s list of examples of merchant categories...more

One Big Misunderstanding: FDIC Clarifies that Caution on Higher-Risk Activity Is Not a Prohibition on Third-Party Payment...

On July 28, 2014, in response to growing pressure from Congress and the banking industry, the Federal Deposit Insurance Corporation (FDIC) issued Financial Institution Letter 41-2014 to clarify its supervisory approach to...more

OCC Issues Updated Risk Management Guidance On Third-Party Relationships

The Office of the Comptroller of the Currency (“OCC”) has revised its risk management guidance on third-party relationships, advising banks to adopt risk management processes that provide more comprehensive oversight and...more

Orrick's Financial Industry Week in Review - November 4, 2013

The Fed Approves New Fee Schedules - On October 31, the Fed announced new fee schedules, effective January 2, 2014, for payment services the Federal Reserve Banks provide to depository institutions (priced services). ...more

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