Control of a Set-aside Entity
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FCPA Compliance and Ethics Report-Episode 63-Managing the Third Party Relationship Under the FCPA, Part I
On June 7, the Office of the Comptroller of the Currency (OCC) issued OCC Bulletin 2017-21 (Frequently Asked Questions to Supplement Bulletin 2013-29; Third-Party Relationships: Risk Management Guidance). This is the OCC’s...more
The bulletin requires relationships between banks and marketplace lenders to be treated with the same rigor of due diligence and ongoing oversight as other relationships with third parties. On January 24, the Office of...more
U.S.-based digital banking startups have raised more than $10 billion since 2010, and investment in financial technology (“fintech”) companies has surpassed $24 billion worldwide. These firms are attempting to disrupt the...more