The Office of the Comptroller of the Currency (OCC) issued an interpretive letter (Letter) on July 22, 2020, stating that national banks and federal savings associations have the authority to provide custody services for...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
For the first time, a U.S. fintech company is acquiring a regulated U.S. bank, which will give it access to a stable and cheaper source of funding – as well as a national bank charter. On February 18th, LendingClub, one of...more
The Situation: The Office of the Comptroller of the Currency ("OCC") has appealed a decision from the Southern District of New York that concluded that the OCC lacks the authority to grant "Fintech Charters" to nondepository...more
In this episode, John ReVeal discusses the background of OCC special purpose charter for FinTechs, including authority and scope. The episode also addresses the concerns and requirements for most FinTechs, including the...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
For two years the Office of the Comptroller of the Currency (“OCC”) solicited comments on how it can support responsible innovation in the financial services industry in order to meet the evolving needs of the consumers,...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