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Tag Archives: FinTech

OCC Guidance Suggests Flexibility for Third-Party Risk Management

Posted in Regulatory Developments

On June 7, 2017, the Office of the Comptroller of the Currency issued frequently asked questions that supplement the OCC’s 2013 guidance entitled “Third-Party Relationships: Risk Management Guidance.” The 2013 Bulletin sets forth the OCC’s expectation for banks’ due diligence and ongoing monitoring of third-party service providers, including enhanced diligence and monitoring for third parties… Read More

CFPB Evaluates Use of Alternative Data and Modeling Techniques in the Consumer Lending Credit Process

Posted in CFPB, Fair Lending, Privacy

On February 16, 2017, the CFPB issued a Request for Information regarding use of alternative data and modeling techniques in the consumer lending “credit process.” The CFPB defines the “credit process” broadly as all processes and decisions made by a creditor during the full life cycle of the credit product, including marketing, pre-screening, fraud prevention,… Read More

Parting Shot: Outgoing Administration Releases FinTech White Paper

Posted in Regulatory Developments

On January 13, 2017, a week before the change in Administration, the Obama White House issued a white paper entitled “A Framework for FinTech” (“White Paper”). The White Paper highlights various FinTech initiatives that were taken by the previous Administration and lays out policy objectives and principles that the Obama White House thought should be… Read More

Financial Services Report – Winter 2016

Posted in Arbitration, Auto Lending, CFPB, Credit Cards, Disparate Impact, Electronic Payments, Enforcement Actions, Fair Lending, Foreclosure, Military Issues, Mobile Payments, Mortgage, Payday Lending, Preemption, Privacy, Regulatory Developments, State Regulators, UDAAP

Hope you survived all of those awkward Thanksgiving holiday conversations—amazing how divided people are on whether the court got it right in the PHH case, isn’t it? So on we go into the holiday season, while visions of Dodd-Frank repeal dance in our heads. No long winter’s nap for the CFPB, not with the inauguration… Read More

EVENT: FinTech Companies and the OCC Special Purpose National Bank Charter

Posted in Events, Regulatory Developments

Thursday, December 8, 2016 11:00 a.m. – 12:00 p.m. PST 2:00 p.m. – 3:00 p.m. EST The Office of the Comptroller of the Currency (OCC) announced in a White Paper that it would begin considering applications from FinTech companies to become “special purpose national banks.” The White Paper includes information about the OCC’s supervisory expectations… Read More

OCC Announces Special Purpose National Bank Charter for FinTech Companies

Posted in Regulatory Developments

On December 2, 2016, Comptroller of the Currency Thomas Curry confirmed that the agency will begin considering applications from FinTech companies to become special purpose national banks, saying that the OCC will charter “financial technology companies that offer bank products and services and meet our high standards and chartering requirements.” The OCC simultaneously released a… Read More

FTC Announces FinTech Forum on Crowdfunding, Peer-to-Peer Payments

Posted in Events, Mobile Payments, UDAAP

On August 3, 2016, the Federal Trade Commission (FTC) released two items in connection with its series of events on the implications of FinTech for consumers. First, the FTC announced it will be hosting the next event in the FinTech Forum series on October 26, 2016. The event will address crowdfunding and peer-to-peer payments. Second,… Read More