conference of state bank supervisors

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Our podcast show today features Professor Dan Awrey of Cornell Law School, and Matt Lambert, Deputy General Counsel of the Conference of State Bank Supervisors (“CSBS”) who discuss the pros and cons of Congress enacting a statute which would require federal charter for non-banks engaged in the payments business. At present, such non-banks are generally required to be licensed by state departments of banking under money transmitter laws.… Continue Reading

In this podcast show, we explore with our repeat guest, Professor Dan Awrey of Cornell University Law School, his working paper “Money and Federalism” in which he advocates for the enactment of Federal legislation creating a Federal charter for non-banks engaged in the payments business, like PayPal and Venmo. The article may be accessed online at SSRN and will likely be published in a law review at some time in the future.… Continue Reading

On July 19, we blogged about comments Acting Comptroller Hsu made before the Exchequer Club on July 17 particularly his decision to review prior OCC preemption determinations in light of the Supreme Court’s recent opinion in Cantero v. Bank of America reversing the Second Circuit’s holding that a New York State law which requires the payment of 2% interest on mortgage escrow accounts is preempted because such law exercises control over a federal power, regardless of the magnitude of its effects.… Continue Reading

The CFPB issued its final rule, titled the Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders Final Rule, on June 3, 2024. The rule will require certain nonbank entities to register certain covered enforcement or court orders, and comply with ongoing, attested reporting requirements on the entity’s compliance with such orders.… Continue Reading

The D.C. federal district court hearing the lawsuit filed by the Conference of State Bank Supervisors (CSBS) seeking to block the Office of the Comptroller of the Currency from granting a national bank charter to Figure Technologies Inc. has entered an order staying the lawsuit.

On June 15, CSBS filed an Unopposed Motion to Stay Litigation in which it referenced Acting Comptroller Hsu’s testimony to the House Financial Services Committee last month in which he indicated that the OCC is currently reviewing the OCC’s framework for chartering national banks.  … Continue Reading

The Office of the Comptroller of the Currency has filed a motion to dismiss the lawsuit filed by the Conference of State Bank Supervisors (CSBS) in D.C. federal district court seeking to block the OCC from granting a national bank charter to Figure Technologies Inc.  The lawsuit represents CSBS’s third challenge to the OCC’s authority to issue special purpose national bank (SPNB) charters to non-depository fintech companies.  … Continue Reading

After looking at CSBS’s role in the system of state financial supervision, we discuss CSBS initiatives to coordinate state licensing and supervision of multi-state non-bank companies, such as by implementing a “one company-one exam” approach and multi-state licensing program, its work on a model law for money services businesses, why CSBS opposes an OCC fintech charter for non-depository companies, and its position on the OCC/FDIC “Madden-fix” rules and OCC “true lender” rule.… Continue Reading

On August 21, 2019 the Conference of State Bank Supervisors (“CSBS”) launched three new online tools designed to help non-bank financial services companies navigate state regulations and protect against cyber security risks: a State Regulatory Guidance Portal, a State Survey Map of Money Transmission Laws, and Cybersecurity 101: A Resource Guide for Financial Sector Executives.… Continue Reading

The Conference of State Bank Supervisors has released a list of 33 companies that will serve as members of its Fintech Industry Advisory Panel.

According to the CSBS, the Advisory Panel’s purpose is “to support state regulators’ increased efforts to engage with financial services companies involved in fintech.”  More specifically, over the next twelve months, Advisory Panel members will participate in at least two in-person meetings with members of the CSBS Emerging Payments and Innovation Task Force and other state banking commissioners “to identify actionable steps for improving state licensing, regulation, and non-depository supervision and for supporting innovation in financial services.” … Continue Reading

The CFPB announced earlier this week that it has established a “framework” with the Conference of State Bank Supervisors (CSBS)  for coordination among the CFPB and state regulators on supervision and enforcement matters.  The framework states that it is “intended to establish a process for coordinated federal/state consumer protection supervision and enforcement of entities providing consumer products or services that are subject to concurrent jurisdiction of the CFPB and one or more [state financial regulatory authorities].” … Continue Reading