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 […]
Continue reading →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 […]
Continue reading →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 […]
Continue reading →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, […]
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 […]
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