Brian McCormally

Arnold & Porter Discusses OCC Plan to Charter FinTech Firms as Special Purpose National Banks

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On December 2, 2016, Comptroller of the Currency Thomas J. Curry announced formally that the Office of the Comptroller of the Currency (OCC) will move forward with chartering financial technology (FinTech) companies that offer bank products and services as special purpose national banks. The announcement was accompanied by the OCC’s release of a guidance paper (Paper) entitled “Exploring Special Purpose National Bank Charters for Fintech Companies” that provided both initial guidance on the special purpose chartering process and posed a set of thirteen questions for public comment.[1] The OCC will accept comments on its Paper until January 15, 2017. … Read more

Arnold & Porter explains New York Takes Lead on Anti-Terrorism and Anti-Money Laundering Enforcement by Proposing Criminal Liability for Compliance Officers

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On December 1, 2015, the New York Department of Financial Services (the DFS) released a proposed rule that would require certain New York-regulated financial institutions (Regulated Institutions) to comply with enhanced anti-terrorism and anti-money laundering (AML) requirements and subject chief compliance officers to potential criminal liability for noncompliance (the Proposal).

The proposed regulations aim to strengthen New York financial institutions’ fight against terrorist financing and money laundering at a time when terrorism concerns are at their highest in years. The Proposal, which was developed by the DFS over several months, also comes amid persistent calls from the general public to … Read more

Arnold & Porter explains First DOJ/CFPB Joint Redlining Settlement

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On September 24, 2015, the US Department of Justice (DOJ), the Bureau of Consumer Financial Protection (CFPB), and Hudson City Savings Bank (Bank) entered into a consent order which, if approved by the court, would settle allegations that the Bank violated the Equal Credit Opportunity Act and the Fair Housing Act (FHA). The consent order is the latest in a series of actions taken by a number of regulators on both the state and federal level settling allegations of redlining based largely on statistical analysis rather than evidence of denied loans.1

The recent settlement was the result of investigations … Read more