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Tag Archives: OCC

OCC Accepting Charter Applications from Fintech Companies

Posted in OCC Fintech Charter
Earlier 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

Update on the OCC’s Initiative for the Special Purpose National Bank Charter

Posted in OCC Fintech Charter
Nineteen months have passed since the Office of the Comptroller of the Currency launched its initiative for fintech companies, specifically asserting the OCC’s authority under the National Bank Act to grant a “special purpose national bank charter.”  In his testimony before Congress last month, the Comptroller of the Currency, Joseph Ottin… Read the rest

OCC Issues Third-Party Relationship Supplemental Examination Procedures

Posted in OCC Fintech Charter
On January 24, 2017, the Office of the Comptroller of the Currency (the “OCC”) issued examination procedures to supplement its 2013 guidance Third-Party Relationships: Risk Management Guidance.  The examination procedures establish expanded procedures for OCC examiners to employ when assessing a national bank’s or federal savings associa… Read the rest

The OCC Fintech Charter: A New Model for Tech-Enabled Financial Services?

Posted in OCC Fintech Charter
On 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

Developments on the OCC’s Initiative for Fintech Companies

Posted in OCC Fintech Charter
Since Comptroller of the Currency Thomas J. Curry announced last December that the OCC will move forward to consider granting special purpose national bank charters to financial technology companies—under the OCC’s existing authorities—the banking industry has grappled with the various dimensions of the agency’s “responsible innovati… Read the rest

OCC to Consider Special Charter Applications for Fintech Companies

Posted in OCC Fintech Charter
On December 2, 2016, Comptroller of the Currency Thomas J. Curry announced that the OCC will move forward with considering granting federal charters—under the OCC’s existing authorities—to financial technology companies.  Comptroller Curry’s action is the latest, clearly most substantial, step forward in administering the “respon… Read the rest

The OCC’s Increasing Focus on BSA-AML Compliance

Posted in Financial Services Litigation and Enforcement
In a speech last week to the Institute of International Bankers, Comptroller of the Currency Thomas J. Curry focused extensively on Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance. Combined with the recent suggestion by Benjamin Lawsky, the Superintendent of New York’s Financial Services Department (DFS), that New York may begin requ… Read the rest

Authorities Regarding GLBA Privacy and the FCRA

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

Added Functionality: Regulatory Issues Associated with Credit and Overdraft Features

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