The Federal Banking Agencies (“FBAs”) — collectively the Office of the Comptroller of the Currency (“OCC”); the Board of Governors of the Federal Reserve System (“Federal Reserve”); the Federal Deposit Insurance Corporation (“FDIC”); and the National Credit Union Administration (“NCUA”) — just issued with the concurrence of FinCEN an Order granting an exemption from the

A portion of the Treasury’s report entitled “A Financial System That Creates Economic Opportunities, Nonbank Financials, Fintech, and Innovation,” focuses on payments.  (See our legal alert for a discussion of other portions of the Treasury’s report.)

Current payment methods.  The report notes four primary core payment systems: credit cards, debit cards, automated

Last week, the OCC released its semiannual risk report highlighting credit, operational, and compliance risks to the federal banking system.  The report focuses on issues that pose threats to those financial institutions regulated by the OCC and is intended to be used as a resource by those financial institutions to address the key concerns

As we reported in an earlier posting, it has taken considerable effort to locate the memoranda of understanding (MOUs) that the CFPB has put in place with various other federal agencies. More of those MOUs recently surfaced through, we believe, a Freedom of Information Act (FOIA) request. One of the newly uncovered MOUs is