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Davis Wright Tremaine LLP

FDIC Rethinks Industrial Banks—Again

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

Davis Wright Tremaine LLP

National Trust Banks – Revisited for Crypto and Payments

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

Venable LLP

Banking on a Nonbank Bank in 2024 - The ILC Option Revisited

Venable LLP on

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

Kilpatrick

Acting Comptroller Explores the Separation of Banking and Commerce

Kilpatrick on

On November 8, Acting Comptroller of the Currency Keith A. Noreika explored how the separation of banking and commerce evolved in the United States and called for a broader discussion of whether the separation continues to...more

K&L Gates LLP

Structuring Bank and Fintech Collaborations

K&L Gates LLP on

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

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