Category Archive: FinTech

Seven State Agreement to License Money Services Businesses

A multi-state licensing agreement (“Compact”), that standardizes certain elements of the licensing process for money services businesses (“MSB”), has been implemented.  MSB include money transmitters, payment service providers, and currency exchangers.  The agreement provides that if one state in the Compact has reviewed certain license requirements such as IT processes, cybersecurity, business plan, background check and compliance […]

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Proposed OCC Fintech Charter

As an update, the Office of the Comptroller of Currency (“OCC”) had proposed a special purpose charter process (“fintech Charter”) for “fintech” or nonbank lenders in 2016.   While fintech lenders were evaluating this licensing opportunity, lawsuits were filed, including one filed by the New York Department of Financial Services (“NYDFS”).  The complaint alleged, certain […]

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Conference Of Bank Supervisors File Complaint Against The OCC Over Fintech Charters

The Conference of State Bank Supervisors (“CSBS”), which represents state chartered banks nationwide, filed suit against the Office of the Comptroller of Currency (“OCC”)  in the US district court of the District of Columbia in April, 2017, regarding  the OCC’s issuance of a new non-bank “fintech charter”. The complaint  alleges that the OCC is over-reaching […]

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CFPB And Commercial Credit

Does the Consumer Financial Protection Bureau (“CFPB”)  have jurisdiction over “commercial credit”? Rep. Emanuel Cleaver II,  raised certain concerns  in a recent letter to the CFPB (the “Cleaver Letter”) , which can help us answer this question.  As we know, fintech lending is based upon the use of algorithms to determine whether to provide commercial […]

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Special Purpose National Bank Charter

On March 15, 2017, the Office of the Comptroller of the Currency (“OCC”), the regulator and chartering authority for national banks and federal savings associations, issued a draft supplement to the Comptroller’s Licensing Manual entitled Evaluating Charter Applications from Financial Technology Companies (“Manual”).  The Manual describes the process through which financial technology (“fintech”) companies may […]

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FINTECH And MARKETPLACE LENDING Bootcamp

There is some confusion in the marketplace with respect to new loan products and services in the banking industry.  My definition of “FINTECH” is broad and encompasses computer programs, applications and other technology used to provide banking and financial services.  Perhaps you have noticed that many retail bank services have been streamlined through on-line payment, […]

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FinTech Strategic Partnership Consulting. A New Product

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 […]

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