Financial Institution Letter FIL-81-2016 The FDIC is seeking comment on a handbook developed to facilitate the process of establishing new banks. Applying for Deposit Insurance – A Handbook for Organizers of De Novo Institutions provides an overview of the business considerations and statutory requirements that de novo organizers will face as they work to establish […]
Continue reading →The Dodd-Frank statute also led to the adoption of Regulation 15G of the Securities and Exchange Act of 1934 (15 U.S.C.A. § 78o-11), which requires the sponsor in a CMBS securitization to retain a 5% stake in the credit risk of the underlying commercial real estate asset. The purported purpose of the regulations is to […]
Continue reading →The Office of the Comptroller of Currency (“OCC”) recently established that it will use its authority to grant special-purpose charter to allow FinTech companies into the banking system. The charter details have not yet been finalized. In order to apply for this special-purpose charter, a company must engage in fiduciary activities, or either one of […]
Continue reading →We consult with marketplace lenders and community banks and other lenders to create a strategic partnership to meet both parties’ business goals. It may be more cost effective to partner with a FinTech provider or marketplace lender than to create a new platform. We offer a value-based consulting product to analyze goals, prepare a strategic […]
Continue reading →The US District Court for the Central District of Ca. granted the Consumer Financial Protection Bureau’s (“CFPB”) Motion for Partial Summary Judgement on August 31, 2016. This is a trial court decision and could be reversed on appeal. The “combination” at issue related to CashCall’s arrangement with Western Sky Financial (“Western”). Western claimed an “affiliation” […]
Continue reading →California Finance Lenders License Purpose: Provide mortgage brokers and lenders with an exemption to other licenses Main Function: A required license for different types of consumer and commercial lending http://codes.lp.findlaw.com/cacode/FIN/1/d9/1/1 http://www.cfllicense.com/ http://media.mofo.com/files/Uploads/Images/140219-Expanded-Commercial-Loan.pdf CALL Report Purpose: A financial report that must be filed by all regulated financial institutions in the U.S. every quarter Main Function: The […]
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