The Georgia Merchant Acquirer Limited Purpose Bank (MALPB) offers a compelling alternative to traditional sponsor bank models by enabling payment processors to directly access card networks like Visa and Mastercard without...more
Industrial banks or industrial loan companies (ILCs)—FDIC-insured banks chartered by certain states, notably Utah—have long been a niche component of the U.S. financial system. These institutions may be owned by commercial...more
In the absence of modern charters and licenses, payments companies and other fintechs—both established financial services providers and new market entrants—must generally obtain 50+ money transmitter and possibly other state...more
Becoming or owning an industrial loan company (or ILC)—the elusive "nonbank bank" option, as Congress coined the term in 1987— still has an allure for financial services providers that want to (1) lend on a national scale...more
On July 31, 2020, the Office of the Comptroller of the Currency (OCC) approved the national bank charter application of Varo Bank, N.A., a wholly-owned subsidiary of fintech Varo Money, Inc. The approved application is for a...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
The Board of Governors of the Federal Reserve System (the Board) issued a much-anticipated final rule (Final Rule) on January 30 to amend and codify—in certain respects, for the first time—its framework for making...more
The Federal Reserve Board has published in the Federal Register a notice of proposed rulemaking with request for comment on a proposal to simplify and increase transparency of its rules for determining control of a banking...more
Many have believed that the national bank “fintech charter” is an ideal solution to providing marketplace consumer loans on a 50-state basis. ...more
In a press release, the organizers of Varo Bank, N.A. announced they have been granted preliminary approval by the OCC of their application to form a de novo national bank, which they claim “put[s] Varo on track to become the...more
On July 31, 2018 the Office of the Comptroller of the Currency (OCC) announced that, effective immediately, it is now accepting national bank charter applications from nondepository financial technology (fintech) companies...more
Some bankers view the rapid rise of “fintech” as an existential threat to traditional banks, especially community banks. But while fintech surely is changing financial services, it is also creating new opportunities for...more
In remarks last week at Georgetown University’s Institute of International Economic Law’s Fintech Week event, Acting OCC Comptroller Keith Noreika provided the “latest on our thinking regarding a charter for fintech companies...more