News & Analysis as of

Federal Reserve FinTech Risk Management

Fenwick & West LLP

Bank-Fintech Partnerships Under Scrutiny: What Fintechs Need to Know About AML Expectations

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Bank-fintech partnerships have transformed the financial services landscape, creating new opportunities and challenges for traditional banking institutions and innovative technology companies alike. In a typical arrangement,...more

Sheppard Mullin Richter & Hampton LLP

Kansas City Federal Reserve Bank Explores Regulatory Risks in Gaming Ecosystems

On April 9, the Federal Reserve Bank of Kansas City published a research briefing examining how video game platforms are reshaping the digital payments landscape. As in-game purchases and platform-based transactions grow in...more

Orrick, Herrington & Sutcliffe LLP

Fed’s Barr speaks on fintech-bank partnerships, generative AI

On April 4, Fed Governor Michael S. Barr spoke at the Federal Reserve Bank of San Francisco about how banks and fintech companies can work together to accelerate the adoption of generative AI in financial services....more

Orrick, Herrington & Sutcliffe LLP

OCC conditionally grants bank’s application for fintech purchase

On March 17, the OCC announced it had conditionally approved an application of a fintech to change the business model of a nationally chartered bank upon acquisition of the bank by the fintech, specifically allowing the...more

Wilson Sonsini Goodrich & Rosati

A Crypto-Friendly Pivot in Bank Supervision: Three Practical Action Items for Innovators

A federal banking agency, the Office of the Comptroller of the Currency (OCC), has smoothed the way for national banks and federal savings associations to engage in crypto-related activities with the issuance of Interpretive...more

Davis Wright Tremaine LLP

OCC Rescinds Required Supervisory "Non-Objection" Preclearance for Permissible Crypto-Related Activities

The OCC has reiterated that certain crypto-related activities—crypto-asset custody, distributed ledger, and stablecoin activities—previously determined to be permissible remain so. The OCC has also rescinded a Biden-era...more

Latham & Watkins LLP

Competing Stablecoin Bills Reflect Consensus and Divergence on Key Issues

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Stablecoin regulation is a top priority for lawmakers, and three recent proposals reflect differing perspectives on how to achieve regulatory clarity while balancing safety and innovation....more

Orrick, Herrington & Sutcliffe LLP

Fed’s Barr discusses generative AI’s potential impact on financial stability

On February 18, Fed Vice Chair for Supervision, Michael S. Barr, delivered prepared remarks at the a conference, discussing the rapid advancements in AI and its potential impact on the economy and financial stability. Barr...more

Cadwalader, Wickersham & Taft LLP

Turn Signal?

What is the direction of bank supervision and regulation under the Trump administration? As one would expect in these early days, the picture is evolving. A little over two weeks ago, the FDIC’s Acting Chairman, Travis Hill,...more

Kilpatrick

Roadmap for Changes to Bank Regulation Under the Trump Administration Begins to Emerge

Kilpatrick on

While the Trump Administration’s approach to bank regulation has been the subject of much speculation, specific proposals have yet to emerge, and the administration has yet to name key personnel in the regulatory agencies. ...more

Paul Hastings LLP

PHFintech: Crypto Policy Tracker - December 13, 2024

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A significant headwind for companies in the digital asset space is that they have reportedly struggled to secure and maintain relationships with banks, in what is now called “Choke Point 2.0.” With the incoming Trump...more

Sheppard Mullin Richter & Hampton LLP

Fed Issues Cease and Desist Order for Crypto-Related Compliance and Risk Management Deficiencies

On September 4, the Federal Reserve Board (Fed) released enforcement actions against a Texas-based bank, addressing regulatory violations and compliance lapses. The Fed, joined by the Texas Department of Banking (TDB),...more

Morrison & Foerster LLP

Banking Agencies Address Banking Arrangements with Third Parties to Provide Deposit Products and Services

On July 25, 2024, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint statement to banks regarding risks...more

Ballard Spahr LLP

Bank Regulators Issue Statement on Third-Party Relationships with Financial Institutions and Publish Request for Information on...

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The federal banking regulators (The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation) issued on July 25 a lengthy joint statement...more

Troutman Pepper Locke

Federal Banking Agencies Reiterate Guidance on Managing Risks Posed By Fintech Partnerships and Other Third Party Relationships

Troutman Pepper Locke on

Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more

Goodwin

10 Considerations for Fintechs Partnering with Community Banks

Goodwin on

As banking and technology become more integrated, banks are increasingly partnering with fintechs to expand their customer offerings. The rapid rise of these partnerships has generated questions for both banks and fintechs on...more

Sheppard Mullin Richter & Hampton LLP

Federal Reserve Board Issues Cease and Desist Order Against Banking-As-A-Service Provider

On June 14, the Federal Reserve Board (Fed) released a cease and desist order against an Arkansas-based banking-as-a-service (BaaS) provider for compliance and risk management failures. As part of the order, the bank is...more

Ballard Spahr LLP

Federal Banking Agencies Issue Guide to Third-Party Risk Management Practices for Community Banks

Ballard Spahr LLP on

On May 3, 2024, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Office of the Comptroller of the Currency (“OCC”) jointly released the...more

McGlinchey Stafford

Deep Dive into Payments: Q&A on Bank Partnership Considerations

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But upon closer consideration, there is an interplay between a bank partner program and the Electronic Fund Transfer Act (EFTA) as implemented by Regulation E, particularly when it comes to timeframes for disputes, liable...more

Morrison & Foerster LLP

Federal Reserve Issues Guidance on Novel Activities, Including Bank-Fintech Partnerships

On August 8, 2023, the Board of Governors of the Federal Reserve System (FRB) issued two Supervision and Regulation Letters (“SR Letters”) that provide guidance on the agency’s supervision of novel activities and the process...more

McGlinchey Stafford

Interagency Guidance on Risks Associated with a Third-Party Relationship

McGlinchey Stafford on

On June 6, 2023, the Board of the Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies) issued...more

Goodwin

Agencies Issue Final Guidance on Third-Party Risk Management

Goodwin on

Agencies Issue Final Guidance on Third-Party Risk Management - On June 6, the Federal Reserve, FDIC, and OCC issued final joint guidance (the Guidance) pertaining to banking organizations’ risk management of third-party...more

Ballard Spahr LLP

Federal banking agencies issue final interagency guidance on risk management in third-party relationships

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The Federal Reserve, FDIC, and OCC have released final interagency guidance for their respective supervised banking organizations on managing risks associated with third-party relationships, including relationships with...more

Venable LLP

Banking Agency Guidance on Third Party Relationships

Venable LLP on

Financial technology companies (fintechs) and other third parties in bank partnerships are routinely subject to scrutiny by their banking partner customers. The Federal Reserve System, the Federal Deposit Insurance...more

Amundsen Davis LLC

Bad Relationships: New Regulatory Guidance for Banks on Managing Risks Associated with Third-Party Relationships

Amundsen Davis LLC on

On June 6, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency jointly released final guidance on managing risks associated...more

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