Richard Potomac (US)

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On November 21, 2018, the Office of the Comptroller of the Currency (the “OCC”), the Board of Governors of the Federal Reserve System (the “Board”), and the Federal Deposit Insurance Corporation (the “FDIC”) (collectively, the “Federal Banking Agencies” or the “Agencies”) jointly issued a notice of proposed rulemaking (the “NPR” or the “Proposal”) that would provide for an optional, simplified measure of capital adequacy for qualifying community banking organizations. The Proposal was issued pursuant to…
On October 25, 2018, the Conference of State Bank Supervisors (“CSBS”) filed a lawsuit in the U.S. District Court for the District of Columbia against the Office of the Comptroller of the Currency (“OCC”) seeking to stop the OCC from issuing any special-purpose national bank charters to financial technology companies that do not receive deposits (“fintech charters”). The CSBS’s lawsuit comes just over a month after New York State Department of Financial Services (“DFS”) Superintendent…
On September 14, 2018, New York State Department of Financial Services (“DFS”) Superintendent Maria T. Vullo filed a lawsuit against the Office of the Comptroller of the Currency (“OCC”) in connection with the OCC’s recent decision to begin accepting applications from nondepository financial technology companies (“fintechs”) for special purpose national bank charters (the OCC’s “Fintech Charter Decision” or “Decision”). Our previous blog posts on the OCC’s fintech charter efforts and related litigation can be found…
On July 31, 2018, the Office of the Comptroller of the Currency (“OCC”) announced its decision to begin accepting applications for special purpose national bank charters from financial technology companies (“fintechs”) that are engaged in the business of banking but do not take deposits. The OCC’s decision comes nearly two years after the agency initially unveiled the proposal in December of 2016. In connection with its announcement, the OCC released a new supplement to the…