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OCC Gives Green Light to Chartering Fintechs as Special Purpose National Banks

USA - August 3 2018 Client Alert The Office of the Comptroller of the Currency announced on July 31 that it will begin accepting applications for special purpose national...

Mark T. Dabertin, Avinoam Erdfarb, Scott D. Samlin.


Regulatory Uncertainty at Federal Level Continues for 'Bank Model' Lending Arrangements

USA - July 17 2018 When differences emerge between the activities of state banks and national banks in the U.S. dual banking system, the root cause typically is a...

Mark T. Dabertin.


New FTC Lawsuit Against Lending Club Provides Helpful Insights

USA - April 26 2018 On April 25, the FTC filed a complaint against Lending Club in the district court for the Northern District of California. The complaint alleges that...

Mark T. Dabertin, Avinoam Erdfarb, Scott D. Samlin.


Lifting of Longstanding OCC Consent Order May Signal Improved Environment for Bank Partnerships

USA - March 20 2018 On February 14, the Office of the Comptroller of the Currency (OCC) terminated a longstanding cease-and-desist order against payday lender ACE Cash...

Mark T. Dabertin, Scott D. Samlin.


The CFPB Under New Leadership: What to Expect in 2018

USA - February 27 2018 Speculation about the future of the Consumer Financial Protection Bureau (CFPB) has been ever-present since Donald Trump’s victory in the 2016...

Mark T. Dabertin, Scott D. Samlin, Richard J. Zack.