News & Analysis as of

Bank Holding Company Act Office of the Comptroller of the Currency

Skadden, Arps, Slate, Meagher & Flom LLP

Federal Regulators Move To Regulate Stablecoins Through Banking Laws Plus New Legislation

The President’s Working Group on Financial Markets (PWG), together with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC), released a much-anticipated Report on...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

Goodwin

Federal Reserve Proposes Rules To Modernize Regulations That Implement CRA

Goodwin on

In the News. The Board of Governors of the Federal Reserve System (Federal Reserve) proposed rules to modernize the regulations that implement the Community Reinvestment Act (CRA); the Conference of State Bank Supervisors...more

Kelley Drye & Warren LLP

The Final Volcker Rule: Implications for Venture Capital

Introduction - As we approach the final quarter of 2020, we thought it would be helpful to recap one of the significant rule changes of the past few months that is likely to benefit venture capital funds and startup...more

Ballard Spahr LLP

Varo Is First FinTech to Receive Full-Service Charter from the OCC

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On July 31, 2020, the Office of the Comptroller of the Currency (OCC) approved the national bank charter application of Varo Bank, N.A., a wholly-owned subsidiary of fintech Varo Money, Inc. The approved application is for a...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

Proskauer Rose LLP

Volcker Rule Amendments: Implications for Asset Managers

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On June 25, 2020, the Federal Reserve Board, the OCC, the FDIC, the SEC and the CFTC (collectively, the "Agencies") adopted amendments (the "Amendments") to the regulations implementing section 13 of the Bank Holding Company...more

Jones Day

Volcker Rule Covered Fund Amendments Provide Clarity and Opportunities

Jones Day on

The Situation: The Federal Reserve, Office of the Comptroller of the Currency ("OCC"), Federal Deposit Insurance Corporation ("FDIC"), Securities and Exchange Commission ("SEC"), and Commodity Futures Trading Commission...more

Morrison & Foerster LLP

Agencies Finalize Amendments To Volcker Rule Covered Fund Provisions

On June 25, 2020, five federal agencies (the “Agencies”) finalized amendments to the rules implementing section 13 of the Bank Holding Company Act of 1956 (the “Volcker Rule”) related to the prohibition on investing,...more

Nutter McClennen & Fish LLP

Nutter Bank Report: February 2020

Federal Reserve Revises Framework for Determining Control of a Banking Organization The Federal Reserve has adopted a final rule to simplify and clarify its regulations for determining control of a banking organization for...more

A&O Shearman

Proposed Revisions to the Volcker Rule

A&O Shearman on

On January 30, 2020, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Securities and Exchange Commission and the Commodity...more

Polsinelli

Proposed Changes to the Volcker Rule

Polsinelli on

On January 30, 2020, the U.S. Securities and Exchange Commission (SEC), the Office of the Comptroller of the Currency, Treasury (OCC), the Board of Governors of the Federal Reserve System (“Fed”), the Federal Deposit...more

Orrick - Finance 20/20

Amendments to the Volcker Rule are Adopted but Leave Much to be Done

Orrick - Finance 20/20 on

On September 18, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (the Board), the Federal Deposit Insurance Corporation, the Securities and Exchange Commission and the...more

K&L Gates LLP

OCC and FDIC Ease “Volcker Rule” Restrictions on Proprietary Trading: SEC, CFTC, and Federal Reserve Expected to Follow Suit

K&L Gates LLP on

On August 20, 2019, the Board of Directors of the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”) approved amendments to regulations implementing Section 13 of the Bank...more

Morrison & Foerster LLP

Amendments to Volcker Rule Regulations

On August 20, 2019, the Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) approved a final rule (the “2019 Final Rule”) to amend the rules implementing Section 13 of the...more

Ballard Spahr LLP

Fed proposal to revise control rules would not create alternative to OCC fintech charter

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The Federal Reserve Board has published in the Federal Register a notice of proposed rulemaking with request for comment on a proposal to simplify and increase transparency of its rules for determining control of a banking...more

Cadwalader, Wickersham & Taft LLP

Marketplace Lending Update #6: Is the Fintech Charter the Solution? Don’t Bank on It

Many have believed that the national bank “fintech charter” is an ideal solution to providing marketplace consumer loans on a 50-state basis. ...more

K&L Gates LLP

Volcker Rule

K&L Gates LLP on

Introduction - This practice note provides an overview of the Volcker Rule, which was enacted in 2010 as Section 619 of the comprehensive Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) and...more

Ballard Spahr LLP

Fintech bank announces preliminary OCC approval of national bank charter

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In a press release, the organizers of Varo Bank, N.A. announced they have been granted preliminary approval by the OCC of their application to form a de novo national bank, which they claim “put[s] Varo on track to become the...more

Troutman Pepper

OCC Gives Green Light To Chartering Fintechs As Special Purpose National Banks

Troutman Pepper on

The Office of the Comptroller of the Currency announced on July 31 that it will begin accepting applications for special purpose national bank charters from nondepository financial technology companies (fintechs) that are...more

Stinson LLP

OCC Now Accepting Charter Applications for Fintech Companies

Stinson LLP on

On July 31, 2018 the Office of the Comptroller of the Currency (OCC) announced that, effective immediately, it is now accepting national bank charter applications from nondepository financial technology (fintech) companies...more

Nutter McClennen & Fish LLP

Nutter Bank Report, July 2018

Headlines - ...Guidance Issued on Immediate Implementation of Certain Provisions of the EGRRCPA ...Federal Appeals Court Rules That the FHFA Is Unconstitutionally Structured ...OCC Issues Updated Guidance on...more

Ballard Spahr LLP

Acting OCC Comptroller Noreika provides further thoughts on SPNB charter proposal

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In remarks last week at Georgetown University’s Institute of International Economic Law’s Fintech Week event, Acting OCC Comptroller Keith Noreika provided the “latest on our thinking regarding a charter for fintech companies...more

Kilpatrick

To Charter or Not to Charter: Initial Thoughts on Recent Fintech & Banking Developments

Kilpatrick on

A topic of increasing interest in recent months and weeks has been whether and if fintech companies would seek to obtain a bank charter of some sort. The recent decisions by Social Finance Inc. (SoFi) and Square, Inc. to...more

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