By

James A. Huizinga

10 January 2020

California Department of Business Oversight December 2019 Actions

The California Department of Business Oversight (CDBO) recently concluded that the point of sale consumer financing programs offered by Sezzle, Inc., and another, unnamed party constituted making loans for purposes of the California Financing Law (CFL). A number of payment providers and technology companies have been developing innovative payment options, … Read More

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06 December 2019

Federal Banking Agencies Release Joint Statement on Use of Alternative Data for Credit Underwriting

On December 3, 2019, the five federal banking agencies1 issued a joint statement (the “Joint Statement”) regarding the use of alternative data for credit underwriting. The Agencies highlighted potential benefits that may arise from the use of alternative data, including the ability to make faster and more accurate credit … Read More

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28 March 2017

Office of the Comptroller of the Currency Issues Draft Fintech Charter Licensing Guidance

On March 15, 2017, the Office of the Comptroller of the Currency published a draft supplement to the Comptroller’s Licensing Manual that sets forth details of the OCC’s proposal to accept applications from financial technology companies for special purpose national bank charters. The OCC’s guidance makes clear that it intends … Read More

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09 December 2016

OCC Moves Forward with Proposal to Issue FinTech Charters

The Office of the Comptroller of the Currency (OCC) has confirmed its intention to explore issuing limited-purpose national bank charters to fintech firms engaged in banking activities — commonly called the “fintech charter.” Earlier this year, the OCC had signaled this possibility. Now, through the release of a policy paper … Read More

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10 December 2015

Federal Trade Commission Bans Certain Payment Methods Under Telemarketing Sales Rule

On November 18, the Federal Trade Commission (FTC) issued final amendments to the Telemarketing Sales Rule (TSR) banning payment methods that the FTC believes are disproportionately used by scammers (the Final Rule). The Final Rule follows the notice of proposed rulemaking (NPRM) that the FTC published on July 9, 2013Read More

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