By Tom Scanlon and Julia Dempewolf on Posted in OCC Fintech CharterEarlier this summer the Office of the Comptroller of the Currency issued the anticipated announcement that fintech companies engaged in the business of banking may apply for special purpose national bank charters. In conjunction with its announcement, the Comptroller of the Currency, Joseph Otting, adopted a Policy Statement describing how the agenc… Read the rest
By Davis Wright Tremaine on Posted in Regulatory and ComplianceOn April 12, 2017, the Office of the Comptroller of the Currency (the “OCC”) issued a Retail Lending booklet (“Booklet”) as part of the Comptroller’s Handbook. The OCC’s Booklet outlines a framework for evaluating retail credit risk management activities and discusses the risks associated with retail lending. The Booklet supplemen… Read the rest
By Davis Wright Tremaine on Posted in OCC Fintech CharterOn February 21, DWT Payments team members Andy Lorentz and Tom Scanlon took part in a discussion organized by NYPAY that focused on the prospects of the OCC special purpose fintech charter. The questions discussed included, “Will the concept survive the many challenges it can be expected to attract, including from fellow regulators? What kind of co… Read the rest
By James H. Mann on Posted in General
One of PLA’s missions is to facilitate knowledge-management for payments practitioners. Pursuant to that mission, PLA is today posting four fundamental, but not always easily accessed, authorities regarding GLBA privacy and the FCRA. Regarding GLBA privacy, we are posting OCC interpretative letters 910 and 917, which remain basic authorities for… Read the rest
By Andrew J. Lorentz on Posted in Regulatory and Compliance
The attached presentation entitled Added Functionality: Regulatory Issues Associated with Credit and Overdraft Features was given by DWT partner Andy Lorentz at American Conference Institute’s 7th National Forum on Prepaid Card Compliance in Washington, D.C. on January 30, 2013.
The presentation covered topics including:
2005 Joi… Read the rest
Our Payments Team addresses changes and continuities in the payments industry every day—leveraging our many years of industry experience and our presence on both coasts and in China. On paymentlawadvisor, we offer commentary on new developments that seem particularly significant, as well as resources that we believe can be helpful to others who are tasked with anticipating, understanding and addressing these developments.