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U.S. sanctions laws present complex conflicts with state insurance laws. While state laws govern the timely payment of claims and other insurance practices, U.S. sanctions administered by the U.S. Department of the Treasury’s...more
In the final days of October, the New York Department of Financial Services (“DFS) published new regulations regarding assessing, licensing, and recordkeeping for pharmacy benefit managers (“PBM”) while revising existing...more
New York has joined the handful of states that are now accepting applications from non-US reinsurers for recognition as a reciprocal jurisdiction reinsurer under new rules that allow US domestic ceding insurers to receive...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
The OCC has filed its reply brief with the Second Circuit in its appeal from the district court’s final judgment in the lawsuit filed by the New York Department of Financial Services (DFS) challenging the OCC’s issuance 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
Bank partnerships allow banks to offer loans to consumers and businesses by leveraging the resources of non-bank entities. The relationships between banks and their non-bank entity partners have existed for many years. In the...more
On Thursday, May 2, 2019, Judge Victor Marrero of the Southern District of New York issued an important decision in the closely watched Vullo v. Office of the Comptroller of the Currency et al., No. 1:18-cv-08377. Judge...more
The Conference of State Bank Supervisors has sued the U.S. Office of the Comptroller of the Currency to prevent it from granting charters for special purpose national banks to non-depository FinTech companies. The CSBS is the...more
On January 17, 2017, Maria Vullo, the Superintendent of the New York State Department of Financial Services (NY DFS) sent a letter to the Office of the Comptroller Currency (OCC), opposing the OCC’s proposed special purpose...more
BELTWAY - Straight Out of the Seventh Circuit The Seventh Circuit recently affirmed a lower court’s ruling that the SEC cannot be sued in district court to stop it from bringing an administrative action. Bebo v. SEC, No....more