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Fintech Guide to Bank Partnerships: A Practical and Legal Roadmap

USA - March 1 2021 Over the past decade, financial technology has revolutionized how financial services are provided to consumers and businesses. Every day, new fintech…

Andrew E. Bigart

Managing Risks in Third-Party Sender ACH Processing

USA - December 14 2020 With much of the economy disrupted as a result of the COVID-19 pandemic, one area that continues to grow is automated clearing house (ACH) payments…

Andrew E. Bigart, Leonard L. Gordon

OCC Proposal Would Prohibit Banks from Denying Services to Entire Industry Categories

USA - November 24 2020 Late last week, the Office of the Comptroller of the Currency (OCC) released a notice of proposed rulemaking (Proposal) that, if adopted, would…

Ellen Traupman Berge, Andrew E. Bigart, D. E. (Ed) Wilson, Jr.

The OCC Draws a Bright Line for Determining the True Lender

USA - October 29 2020 With just two sentences and fewer than 70 words, the Office of the Comptroller of the Currency (OCC) has attempted to finally resolve the Madden…

R. Andrew Arculin, Allyson B. Baker, Makalia A. Griffith

Charter Fight Flares Up Again Amid OCC's Push for Payments Companies

USA - September 2 2020 The Conference of State Bank Supervisors (CSBS) issued a terse, three-sentence warning for the OCC to back off its plan to offer a payments charter…

Allyson B. Baker, Andrew E. Bigart