The FDIC has issued a proposed rule that would apply to practically all bank-fintech arrangements that use custodial deposit accounts to provide customers with transactional features (also called "FBO" accounts for short)....more
One of the biggest challenges for fintechs is ensuring that their services comply with federal and state money transmission laws. For example, a fintech operating as a payment facilitator faces significant money transmission...more
The Board of Governors of the Federal Reserve (the "Federal Reserve") has over several decades defined when an activity engaged in by foreign banks subject to the Bank Holding Company Act of 1956 (the "BHCA"), which are thus...more
With the regulatory agenda for the US operations of foreign banks in a state of flux, Kevin Petrasic, Paul Saltzman, Glen Cuccinello, Will Giles and Alexander Abedine of global law firm White & Case provide a map to help...more
On January 18, 2018, the Board of Governors of the Federal Reserve System (the “Federal Reserve Board”) announced the approval of proposed revisions to the Annual Report of Foreign Banking Organizations (“FR Y-7”). The...more
On Friday, October 30, 2015, the Federal Reserve Board (“Board”) reaffirmed its commitment to both the bank holding company model and single point of entry resolution. In a departure from historical views of the purpose and...more
1. Question: What is the Volcker Rule, and when does it take effect? Answer: The Volcker Rule was enacted into law as section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank...more
The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 contains two sets of provisions for managing the insolvency of financial institutions. First, the legislation creates an Orderly Liquidation Authority...more