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On July 25, 2024, the federal banking agencies issued a joint statement flagging potential risks in bank-fintech arrangements, along with a request for public information (RFI) on the benefits, risks, and risk management...more
Out of recent banking agency focus on fintech-bank partnership arrangements, we’ve had a number of fintech clients inquire about the questions they should ask potential bank partners in due diligence. This Fintech Flash...more
Federal Regulation Actions Frozen Pending Review from New Administration - On January 20, 2021, newly inaugurated President Joe Biden issued a memorandum to the Heads of Executive Departments and Agencies asking current...more
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
On December 23, 2019, the New York Department of Financial Services (NYDFS) issued an Industry Letter instructing each institution it regulates, including banks and licensed Fintechs, to make submissions describing the...more
In February 2019, the CFPB released the highly anticipated revamp of its Payday Rule, reinforcing its more lenient attitude towards payday lenders. In light of the Bureau’s softer touch, as well as similar developments at 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
Given the heavily regulated nature of financial services in the United States, it should not be a surprise that one of the biggest challenges facing the “fintech” industry is regulatory uncertainty. As explained by the...more
In this newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset managers and...more
On October 26, 2016, the Office of the Comptroller of the Currency (“OCC”) issued its Recommendations and Decisions for Implementing a Responsible Innovation Framework (“Framework”). The Framework is a follow up to the OCC’s...more
What are federal regulators doing with regard to oversight of emerging financial technology? That question is at the heart of a letter Sens. Sherrod Brown (D-Ohio) and Jeff Merkley (D-Ore.) recently sent to the leaders of the...more