Pratin Vallabhaneni

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 US Policy Developments in FinTech and Payments Systems: Federal Reserve Establishes Tasks Forces of Faster Payments and Secure Payments

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FinTech businesses focused on payments systems and foreign exchange have witnessed an explosion of demand in recent years. As these payment systems services continue to gain mainstream acceptance, financial regulators in the US are increasingly interested in monitoring and, as appropriate, prescribing policies or regulations concerning them, slowly casting a prudential regulatory framework over the FinTech payments systems industry.[1] The policy and regulatory landscape in this area is undergoing fundamental change.

Background

Regulation of the US payment system is highly fragmented and often ad hoc. In the foreign exchange sector, for instance, the appropriate regulator and the nature of the … Read more