As we begin the 119th Congress, the nation is also preparing for the new administration to take office in just a few weeks. While federal action on digital assets remains a key focus, this week’s Crypto Policy Tracker shifts...more
The D.C. federal district court hearing the lawsuit filed by the Conference of State Bank Supervisors (CSBS) seeking to block the Office of the Comptroller of the Currency from granting a national bank charter to Figure...more
On March 9, a three-judge panel of the Second Circuit heard oral argument on the question of whether the OCC can legally issue national bank charters to non-depository financial technology (fintech) firms. The case is...more
The Conference of State Bank Supervisors (CSBS) has filed a lawsuit in D.C. federal district court to block the OCC from granting a national bank charter to Figure Technologies Inc. According to the complaint, Figure,...more
On September 15, the Conference of State Bank Supervisors (CSBS) announced that money transmitters operating in 40 or more states will be able to take advantage of a new, comprehensive exam designed to satisfy all state money...more
The Conference of State Bank Supervisors (CSBS) recently announced plans to establish a program under which money transmitters licensed in multiple states will undergo a single comprehensive exam that seeks to satisfy all...more
On September 15, 2020, the Conference of State Bank Supervisors (“CSBS”) announced the launch of a new program intended to streamline the exam process required by state regulatory agencies for the nation’s payments firms and...more
Despite often operating on a nationwide scale, fintech companies rarely meet the stringent requirements for obtaining a national banking charter. Under the current regulatory landscape, these companies must therefore secure...more
On July 23, 2020, the New York Department of Financial Services (“DFS”) filed its appellate brief asking the Second Circuit Court of Appeals to uphold the lower court’s decision to block the Office of Comptroller of the...more
On March 19, 2019, the New York State Department of Financial Services (“NYDFS”) filed a brief in opposition to the Office of the Comptroller of the Currency’s (“OCC”) motion to dismiss the NYDFS’ lawsuit challenging the...more
1. FDIC Proposes Changes to Deposit Insurance Assessment Rule for CBLR Banks The FDIC has published a proposal that describes how the agency would apply the Community Bank Leverage Ratio (“CBLR”) framework previously...more
Some commenters have opined that the litigation risk surrounding the Office of the Comptroller of the Currency’s (“OCC”) proposed special purpose national bank charter for Fintechs (“Fintech Charter”) is deterring applicants...more
On October 25, 2018, the Conference of State Bank Supervisors (CSBS) renewed its lawsuit against the Office of the Comptroller of the Currency (OCC) seeking to prevent the OCC from issuing its long awaited special-purpose...more
On September 12th, the Conference of State Bank Supervisors (CSBS) announced that it would again pursue litigation in opposition to the OCC’s recent decision to accept applications from non-depository financial technology...more
On April 30, 2018, the United States District Court for the District of Columbia dismissed a lawsuit filed one year earlier by the Conference of State Bank Supervisors (CSBS) disputing the authority of the Office of the...more
On April 30, 2018, the U.S. District Court for the District of Columbia dismissed the lawsuit filed by the Conference of State Bank Supervisors (CSBS) in April 2017 challenging the Office of the Comptroller of the Currency’s...more
Earlier this week, the Conference of State Bank Supervisors (CSBS) announced that seven states have agreed to a multi-state compact that standardizes key elements of the licensing process for money services businesses (MSB). ...more
One year ago, the Office of the Comptroller of the Currency (OCC) decided to move forward with considering applications from financial technology (fintech) companies to become special purpose national banks. In early 2017,...more
A New York federal district court has dismissed the lawsuit filed by the New York Department of Financial Services (DFS) challenging the OCC’s authority to grant special purpose national bank (SPNB) charters to nondepository...more
The Conference of State Bank Supervisors has released a list of 33 companies that will serve as members of its Fintech Industry Advisory Panel. According to the CSBS, the Advisory Panel’s purpose is “to support state...more
The Office of the Comptroller of the Currency (OCC) has filed a motion to dismiss the lawsuit filed by the New York Department of Financial Services (DFS) challenging the OCC’s authority to grant special purpose national bank...more
On May 10, the Conference of State Bank Supervisors (CSBS) announced a series of initiatives (branded as Vision 2020) designed to modernize state regulation of non-banks. The announcement specifically calls out financial...more
The New York Department of Financial Supervision (DFS) has filed a complaint in a New York federal district court to stop the Office of the Comptroller of the Currency (OCC) from implementing its proposal to issue special...more
Last week, a group of state regulators, the Conference of State Bank Supervisors ("CSBS"), filed suit in the U.S. District Court for the District of Columbia seeking to enjoin the Office of the Comptroller of the Currency...more
The CSBS’ request for an injunction may prompt the OCC to slow down or abandon its willingness to consider issuing national bank charters to fintech companies....more