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
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
The OCC recently finalized two broad updates to its regulations that increase flexibility for regulatory filings, including for corporate transactions such as business combinations, and update and clarify permissible...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
The U.S. Office of Comptroller of the Currency published a notice of proposed rulemaking regarding permitting federal savings associations with total consolidated assets of $20 billion or less as of December 31, 2017...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
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
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