To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more
The Conference of State Bank Supervisors (CSBS), a nationwide organization of state banking and financial regulators from all 50 states, the District of Columbia, and U.S. territories, has raised significant concerns...more
The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more
The OCC announced this week that it has conditionally approved applications from Social Finance Inc. (SoFi) to create SoFi Bank, National Association (SoFi Bank, N.A.), as a full service national bank headquartered in...more
The Conference of State Bank Supervisors (CSBS) has withdrawn its lawsuit filed in D.C. federal district court in December 2020 seeking to block the OCC from granting a national bank charter to Figure Technologies Inc. The...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
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
The Office of the Comptroller of the Currency has filed a motion to dismiss the lawsuit filed by the Conference of State Bank Supervisors (CSBS) in D.C. federal district court seeking to block the OCC from granting a national...more
Federal Financial Regulators Seek Information on the Use of AI by Financial Institutions - On March 29, 2021, five federal financial regulatory agencies (the Federal Reserve, CFPB, FDIC, OCC, and NCUA) announced a request...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
FDIC Creates New Exceptions for Fintech Companies with Its Final Brokered Deposit Rule - On December 15, 2020, the Federal Deposit Insurance Corporation (FDIC) finalized its updated brokered deposit rule, providing...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, 2020, the Conference of State Bank Supervisors (CSBS) announced a “one company, one exam” program for examinations of money services businesses. These businesses, spanning from money transmitters like PayPal...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
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
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 June 25, 2020, Acting Comptroller Brian Brooks announced that the Office of the Comptroller of the Currency (the “OCC”) intends to introduce the first in a series of at least two national bank charters for payments...more
In This Issue. The Office of the Comptroller of the Currency (OCC) finalized a rule to strengthen and modernize regulations under the Community Reinvestment Act; the Securities and Exchange Commission (SEC) voted to adopt...more
Brian Brooks, Chief Operating Officer of the Office of the Comptroller of the Currency (“OCC”) said on Monday that he believes the OCC should investigate the viability and utility of a non-depository payments charter: “One of...more
(New information added on April 17, 2020) - As the coronavirus crisis unfolds, federal and state financial services regulatory agencies have taken multiple actions impacting banks, non-bank financial service providers, and...more
The three US federal banking agencies continue to take additional steps to promote the functioning of the financial system in the face of the pandemic. The three US federal banking agencies - the Board of Governors of the...more
Our Financial Services & Products Group examines how federal regulators – speaking with a single voice – will view loan modifications during the coronavirus pandemic....more
The Office of Comptroller of the Currency (the OCC) has published its 2019 annual report (the Annual Report), which summarized the OCC’s strategic priorities for 2019. The Annual Report also highlighted the OCC’s key...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