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Banking Sector Recordkeeping Requirements FinTech

Hudson Cook, LLP

CFPB Files Action against Fintech Bank Partner for Alleged Unfair Practices Related to Record Keeping of Consumer Funds

Hudson Cook, LLP on

On August 21, 2025, the Consumer Financial Protection Bureau filed an enforcement action in connection with Chapter 11 bankruptcy proceedings for a fintech (the "Fintech") acting primarily as a third-party service provider...more

Mayer Brown

FDIC’s New Recordkeeping Proposal

Mayer Brown on

Last month, the FDIC proposed rules related to FDIC pass-through insurance coverage. These rules could have a significant impact on bank-fintech partnerships, including some partnerships for programs that do not promise FDIC...more

Venable LLP

Custody Battles: The FDIC's Latest Proposed Rule on FBO Accounts

Venable LLP on

The FDIC has issued a proposed rule that would apply to practically all bank-fintech arrangements that use custodial deposit accounts to provide customers with transactional features (also called "FBO" accounts for short)....more

Goodwin

OCC Finalizes “True Lender” Rule

Goodwin on

In the News. The Office of the Comptroller of the Currency (OCC) finalized its “true lender” rule, which establishes that a national bank or federal savings association (bank) is the “true lender” of a loan if, as of the...more

Vedder Price

The OCC Speaks: How FinTech Applications Will Be Reviewed

Vedder Price on

On March 15, 2017, the Office of the Comptroller of the Currency (the “OCC”) published for comment a draft supplement to the OCC’s existing Comptroller’s Licensing Manual providing detail on how the OCC will evaluate national...more

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