May 30, 2024 - The Federal Reserve Board published a working paper entitled, “Central Banking Post Crises.” May 30, 2024 - The Federal Reserve Board published a working paper entitled, “Constructing high-frequency...more
On August 9, 2022, the Conference of State Bank Supervisors (CSBS) released two cybersecurity tools for nonbank financial services institutions to help prepare for state cybersecurity exams and, ultimately, improve...more
The U.S. Court of Appeals for the Second Circuit revived the Office of the Comptroller of the Currency’s (OCC) controversial special-purpose national bank charter that had been challenged by the New York Department of...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
When the calendar turned to 2020, my first thought was about how futuristic the year sounded and what kind of interesting things it had in store. At that time, no one could possibly have imagined that some of those...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
The OCC has appealed to the Second Circuit from the district court’s final judgment entered in October 2019 in the lawsuit filed by the New York Department of Financial Services seeking to block the OCC’s issuance of special...more
Judge Dabney Friedrich of the U.S. District Court for the District of Columbia has dismissed a lawsuit brought by the Conference of State Bank Supervisors (CSBS) that would have prevented the Office of the Comptroller of the...more
On September 3, 2019, Judge Dabney Friedrich of the U.S. District Court for the District of Columbia dismissed the Conference of State Bank Supervisors’ (“CSBS”) second suit challenging the Office of the 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
The New York Department of Financial Services has filed a memorandum of law opposing the OCC’s motion to dismiss the NYDFS’s second lawsuit seeking to block the OCC’s issuance of special purpose national bank (SPNB) charters...more
As expected, the OCC filed a motion to dismiss the second lawsuit filed by the New York Department of Financial Services (DFS) in a New York federal district court to block the OCC’s issuance of special purpose national bank...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 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
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
Below is a summary of some of the significant legal and regulatory actions that occurred over the past week. This alert is not intended to be a comprehensive list of all such developments, but rather a selection of...more
Editor's Note - The Dual Banking System is Working. In the April 26 edition of the Roundup, we noted that the Conference of State Bank Supervisors (CSBS) had sued the Office of the Comptroller of the Currency (OCC),...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
As legislators grapple with creating legislation intended to bring virtual currencies, such as bitcoin, within the scope of anti-money laundering regulations, the vulnerability of Bitcoin exchanges to theft and other cyber...more
Addressing regulatory concerns pertaining to consumer protection, market stability, and law enforcement, the Framework expands on the CSBS draft framework released in December 2014. The Conference of State Bank...more
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