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Are You a Money Transmitter in Connecticut? In Hawaii?

As we have noted previously, one of the defining aspects of the payments revolution of the past few years—at least from a regulatory perspective—has been the question of whether a particular payments service is subject to...more

OCC Acting Comptroller Woos Fintech Companies with Remarks on Online Lending

On September 25, 2017, Acting Comptroller of the Currency Keith Noreika discussed online lending and innovation in his keynote remarks prepared for delivery to the Online Lending Policy Summit in Washington, D.C. Consistent...more

Financial Services Report - Fall 2017

EDITOR’S NOTE - Through hurricanes, wild fires, the publication of Hillary Clinton’s book, the birth of Amal and George Clooney’s twins, and the Dodgers’ historic losing streak, Director Richard Cordray and the CFPB’s...more

OCC Releases Semiannual Risk Perspective: Fintech is Risky?

On July 7, 2017, the Office of the Comptroller of the Currency (“OCC”) released its Semiannual Risk Perspective report (the “Report”) identifying the risks faced by national banks and federal savings associations in the ...more

Financial Services Report - Summer 2017

EDITOR’S NOTE - Summer blockbuster season is officially upon us. Have you seen Wonder Woman yet? What about Guardians of the Galaxy Part 2? It’s déjà vu all over again with Baywatch, Pirates of the Caribbean, Alien,...more

FDIC Action Is a Reminder that Bank Partnerships Are Not a Panacea for Non-Banks

On May 11, 2017, the Federal Deposit Insurance Corporation (FDIC) announced that it had reached settlements with Bank of Lake Mills (Bank) and two of its “institution-affiliated parties” (IAPs)—Freedom Stores, Inc. (FSI) and...more

CFPB Files Suit Challenging Tribal-Affiliated Lenders Using its UDAAP Authority

On April 27, 2017, the Consumer Financial Protection Bureau (“CFPB”) filed a complaint in a federal district court in Illinois against four online tribal-affiliated lenders alleging that the lenders violated the Truth in...more

Financial Services Report - Spring 2017

EDITOR’S NOTE - In like a lion, out like a lamb—it works for weather; does it work for new administrations? We’ll have to wait and see. We’ll have to wait and see about the length of CFPB Director Richard Cordray’s...more

Financial Services Report, Winter 2016

EDITOR’S NOTE - Hope you survived all of those awkward Thanksgiving holiday conversations— amazing how divided people are on whether the court got it right in the PHH case, isn’t it? So on we go into the holiday season,...more

OCC Announces Special Purpose National Bank Charter for FinTech Companies

On December 2, 2016, Comptroller of the Currency Thomas Curry confirmed that the agency will begin considering applications from FinTech companies to become special purpose national banks, saying that the OCC will charter...more

OCC Lays Out Responsible Innovation Framework

On October 26, 2016, the Office of the Comptroller of the Currency (“OCC”) issued its Recommendations and Decisions for Implementing a Responsible Innovation Framework (“Framework”). The Framework is a follow up to the OCC’s...more

Financial Services Report, Fall 2016

Editor’s Note - So much for summer! The weather is cooling, the kids are back to school, and we better not see you wearing white so long after Labor Day! For those of you having a little trouble getting back in the...more

Senators Ask Banking Agencies to Outline FinTech Oversight

On July 21, 2016, Senators Sherrod Brown (D-Ohio) and Jeff Merkley (D-Ore.) sent a letter to the heads of five federal agencies requesting that they outline the steps they are taking to “ensure effective oversight” of the...more

OCC Announces Preliminary Framework on FinTech and Responsible Innovation

On March 31, 2016, the Office of the Comptroller of the Currency (“OCC”) released a white paper on financial technology innovation (“White Paper”), which lays out a preliminary framework for “responsible innovation.” The...more

4/7/2016  /  Banking Sector , CFPB , FinTech , Innovation , OCC

CFPB Calls for Complaints About Marketplace Lenders

On March 7, 2016, the Consumer Financial Protection Bureau (“CFPB”) made its first official moves on “marketplace lending,” which also may be known as “peer-to-peer” lending. The CFPB described marketplace lending as the use...more

CFPB Publishes No-Action Letter Policy Statement

On February 22, 2016, the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) published its Final Policy Statement (“Final Policy”) on No-Action Letters (“NALs”). The Final Policy follows a Proposed Policy on...more

Are You a “Payment Processor”? Washington State Appears to Significantly Expand Scope of Its Money Transmission Act

One of the defining aspects of the payments revolution of the past few years—at least from a regulatory perspective—has been the question of whether any particular payments service is subject to regulation as money...more

CFPB Takes Action Against Lead Aggregators

On December 17, 2015, the Consumer Financial Protection Bureau (“CFPB”) announced that it has taken action against lead aggregators that resold sensitive personal information to lenders and debt collectors. In a complaint...more

Loan to San Bernardino Attacker Generates New Focus on Online Marketplace Lending and Terrorism Financing

News that an online marketplace lender extended a $28,500 loan to Syed Rizwan Farook, one of the alleged San Bernardino attackers, just two weeks before the attack, has spurred House Financial Services Committee Chairman Jeb...more

The CSBS Finalizes Model Framework for Virtual Currencies

On September 15, 2015, the Conference of State Bank Supervisors (“CSBS”) issued its final Model Regulatory Framework on virtual currency activities (“Final Framework”). The Final Framework follows the CSBS’s December 2014...more

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