By

Joel D. Feinberg

17 August 2021

FFIEC Guidance on Authentication and Access to Financial Institution Services and Systems

On August 11, 2021, the Federal Financial Institutions Examination Council (FFIEC)1 issued guidance establishing risk management principles and practices to support the authentication of users accessing a financial institution’s information systems and customers accessing a financial institution’s digital banking services (the Guidance). The Guidance is not intended to serve … Read More

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12 June 2020

The U.S. Office of the Comptroller of the Currency Seeks Comment on Digital Innovation by Banks

The U.S. Office of the Comptroller of the Currency (OCC) has issued an Advance Notice of Proposed Rulemaking (ANPR)1 seeking input on how best to accommodate new technology and innovation in the business of banking, in connection with the OCC’s “comprehensive review” of its regulations at 12 C.F.R. part … Read More

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23 March 2020

U.S. Office of the Comptroller of the Currency Updates Third-Party Relationships Risk Management Guidance

On March 5, 2020, the Office of the Comptroller of the Currency (OCC) issued an updated set of answers to frequently asked questions (FAQs)1 regarding risk management in national bank relationships with third parties to further supplement its 2013 guidance, OCC Bulletin 2013-29 (the Bulletin),2 and its 2017 … Read More

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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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20 September 2018

New York State Department of Financial Services Challenges OCC Authority on Fintech Charters

On July 31, 2018, the U.S. Office of the Comptroller of the Currency (OCC) announced its decision (the Fintech Charter Decision) to begin accepting applications from financial technology (fintech) companies for special purpose national bank charters.1 The OCC has indicated it will not grant a charter to a fintech … Read More

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22 August 2018

Fintech Without Borders: Regulators Consult on Global Financial Innovation Network

On August 7, a group of regulators from 11 jurisdictions published a consultation (the Consultation) on the Global Financial Innovation Network (the GFIN), which aims to promote international cooperation on innovation and the use of technology in financial services (FinTech) and in regulatory processes (RegTech).

The group — which includes

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05 June 2018

President Trump Signs Financial Services Regulatory Reform Legislation

On May 24, 2018, President Donald Trump signed into law the Economic Growth, Regulatory Relief, and Consumer Protection Act (the Act). The Act is effective immediately except as otherwise stated in certain provisions.

The Act makes many significant modifications to the postcrisis financial regulatory framework, although it leaves the core

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10 April 2018

Financial Crimes Enforcement Network Issues New Frequently Asked Questions on Customer Due Diligence Requirement

On April 3, 2018, the Financial Crimes Enforcement Network (FinCEN) issued new frequently asked questions (FAQs) regarding its customer due diligence rule (CDD Rule).

The CDD Rule applies to banks, broker-dealers in securities, mutual funds, futures commission merchants and introducing brokers in commodities (collectively, covered financial institutions or CFIs).

The

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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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