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This second installment in a series of insights on bank charter considerations describes the consequences of operating through an insured depository institution charter, including capital requirements, supervision and...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 New York Department of Financial Services (DFS) has filed its opening brief with the Second Circuit in the OCC’s appeal from the district court’s final judgment in DFS’s lawsuit challenging the OCC’s issuance of special...more
On March 17, the FDIC released for public comment a proposed rule for industrial banks and industrial loan companies (together, “ILCs”) and their parent companies and signaled that it is considering two pending ILC...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
The Office of the Comptroller of the Currency announced on July 31 that it will begin accepting applications for special purpose national bank charters from nondepository financial technology companies (fintechs) that are...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
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
A topic of increasing interest in recent months and weeks has been whether and if fintech companies would seek to obtain a bank charter of some sort. The recent decisions by Social Finance Inc. (SoFi) and Square, Inc. to...more