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
This is the first in a series of articles in our "So, You Want to Be a Bank?" series. More than 1,000 new banks were formed in the eight years before the Great Recession began in 2008. In comparison, the past 15 years...more
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
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
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 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
The Office of the Comptroller of the Currency ("OCC") announced on December 20, 2016 that it is adopting a final rule to implement provisions of the National Bank Act that provide the legal framework for receiverships for...more