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On April 3, 2023, the Conference of State Bank Supervisors (CSBS) released an update on the status of its State Examination System (SES).  The SES is an examination system that is intended, in part, to foster standardization and enable state-level coordination by providing a platform for state agencies, regulators, and companies to conduct company exams from start to finish.… 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

The Conference of State Bank Supervisors (CSBS) has filed a lawsuit in D.C. federal district court to block the OCC from granting a national bank charter to Figure Technologies Inc.  According to the complaint, Figure, through a subsidiary, is currently licensed in 49 states and the District of Columbia as a mortgage lender, consumer lender, and/or debt collector and intends to begin engaging in new money transmission activities in early 2021 through another subsidiary. … Continue Reading

The Conference of State Bank Supervisors (CSBS) recently announced plans to establish a program under which money transmitters licensed in multiple states will undergo a single comprehensive exam that seeks to satisfy all state examination requirements, beginning in 2021. Money transmitters, payments firms and cryptocurrency companies licensed in 40 or more states would be covered by the program, to be known as “MSB Networked Supervision”.… Continue Reading

As expected, the OCC filed a motion to dismiss the second lawsuit filed by the New York Department of Financial Services (DFS) in a New York federal district court to block the OCC’s issuance of special purpose national bank (SPNB) charters to fintech companies.  The OCC also filed a reply brief in support of its motion to dismiss the second lawsuit filed by the Conference of State Bank Supervisors (CSBS) in a D.C.… Continue Reading

Earlier this month, the Conference of State Bank Supervisors (CSBS) filed a brief opposing the OCC’s motion to dismiss the second lawsuit filed by CSBS to stop the OCC from issuing special purpose national bank (SPNB) charters to fintech companies.  That brief was accompanied by an “Alternative Motion for Leave to Conduct Discovery” filed by CSBS.… Continue Reading

The Conference of State Bank Supervisors (CSBS) announced last week that it has agreed to implement 14 recommendations made by its Fintech Industry Advisory Panel (Advisory Panel).

The Advisory Panel was formed in 2017 to identify actionable steps for improving state licensing, regulation, and non-depository supervision and for supporting innovation in financial services. … Continue Reading

On September 12th, the Conference of State Bank Supervisors (CSBS) announced that it would again pursue litigation in opposition to the OCC’s recent decision to accept applications from non-depository financial technology firms for a special purpose national bank (SPNB) charter.

While it announced that its Board of Directors had approved renewing litigation against the OCC at an August 28 meeting, the CSBS did not indicate when it plans to file the lawsuit. … Continue Reading

The Office of the Comptroller of the Currency (OCC) has filed a motion to dismiss the lawsuit filed by the New York Department of Financial Services (DFS) challenging the OCC’s authority to grant special purpose national bank (SPNB) charters to nondepository fintech companies.

The DFS lawsuit, which was filed in May 2017 in a New York federal district court, is similar to the lawsuit filed in April 2017 by the Conference of State Bank Supervisors (CSBS) in D.C.… Continue Reading