Consumer Finance Monitor Podcast Episode: Should Congress Create a New Federal Charter for Non-Bank Payments Companies?
This third installment in our series of insights on bank charter considerations describes the process for seeking regulatory approval to form or acquire a bank....more
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
One of the beauties of the national banking system is that it allows state-chartered banks to offer uniform credit products across the 50 states without having to worry about state interest rate caps. This concept - rate...more
Whenever discussing bank charter types, I’m reminded of a comparison made by Walt Moeling. Walt would always say that the bank charter choice is like choosing between a Ford and a Chevy truck. There are strong, die-hard...more
Given the heavily regulated nature of financial services in the United States, it should not be a surprise that one of the biggest challenges facing the “fintech” industry is regulatory uncertainty. As explained by the...more
The U.S. depository industry has continued its path of consolidation, but as of the end of 2017, there are still over 5,600 banks chartered in the United States. This represents a decline of just under 3,000 charters from...more
On October 27, 2017, the Office of the Comptroller of the Currency (OCC) issued a full-service national bank charter since the financial crisis to Winter Park National Bank. Winter Park National Bank is the first de novo...more
The Office of the Comptroller of the Currency (OCC) recently came one step closer to making its fintech bank charter a reality. On Wednesday, March 15, it released a Licensing Manual Supplement (Supplement) with proposed...more
The New York State Department of Financial Services (NYDFS) has come out strongly against an Office of the Comptroller of the Currency (OCC) proposal to grant national bank charters to financial technology (fintech)...more