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The OCC and FDIC have filed a joint amicus brief in a Colorado federal district court arguing that the court should affirm the decision of a bankruptcy court holding that a non-bank loan assignee could charge the same interest rate the bank assignor could charge under Section 27(a) of the Federal Deposit Insurance Act, 12…

The D.C. federal district court has granted the OCC’s motion to dismiss the lawsuit filed by the Conference of State Bank Supervisors (CSBS) to block the OCC from issuing special purpose national bank (SPNB) charters to fintech companies.

The CSBS lawsuit was the second lawsuit filed by CSBS attempting to block the OCC from issuing…

On July 31, 2019, the Office of the Comptroller of the Currency (the “OCC“) released OCC Bulletin 2019-40 (the “Bulletin”) detailing guidelines for national banks, federal savings associations and federal branches of foreign banking organizations subject to the Community Reinvestment Act (the “CRA”) requesting designation as a wholesale or limited purpose bank under…

Opposition from state regulators to the OCC’s decision to issue special purpose national bank (or fintech) charters continues to be vigorous.  In this podcast, we review the charter’s potential benefits, assess the legal arguments made by its opponents, discuss the federal court decision refusing to dismiss the NY banking regulator’s lawsuit, why we think it’s…

Last Thursday, the OCC filed a letter with the New York federal district court hearing the lawsuit filed by the New York Department of Financial Services (NYDFS) seeking to block the OCC’s issuance of special purpose national bank (SPNB) charters to fintech companies in which the OCC advised the court that it will be conferring…

The OCC’s Semiannual Risk Perspective report focuses on key issues that pose threats to bank safety and soundness and legal compliance.  Among such issues discussed in the Spring 2019 report, which generally reflects bank data as of December 31, 2018, are risks arising from financial innovation and new technologies.

One of the most significant…

The Federal Reserve Board has published in the Federal Register a notice of proposed rulemaking with request for comment on a proposal to simplify and increase transparency of its rules for determining control of a banking organization.  The proposal’s comment period closes on July 15, 2019.

The proposed revisions to the Board’s control regulations would…

The Office of the Comptroller of the Currency (OCC) has opened its own “sandbox” through a Proposed Innovation Pilot Program (Program) designed to promote its innovation initiatives, add value through proactive supervision, and continue its objective to lead fintech innovation expansion. The comment period for the Program is open until June 14, 2019.

The Program…

The New York Department of Financial Services has filed a memorandum of law opposing the OCC’s motion to dismiss the NYDFS’s second lawsuit seeking to block the OCC’s issuance of special purpose national bank (SPNB) charters to fintech companies.

In its motion to dismiss, the OCC argued that the court lacks subject matter jurisdiction…