The Office of the Comptroller of the Currency, Treasury (OCC), the Board of Governors of the Federal Reserve System (Board), and the Federal Deposit Insurance Corporation (FDIC) recently announced a “Notice of Proposed Rulemaking for the Computer-Security Incident Notification Requirements for Banking Organizations and Their Bank Service Providers.” This new rule would require a banking
Treasury
ILCs, the OCC, and the Future of Fintech Banking
By Norman Roos on
Posted in Enforcement + Litigation
Industrial Loan Companies (ILCs) are a different kind of financial institution. The ILC is a state-chartered FDIC-insured depository financial institution with certain advantages common to banks but without all of the corresponding regulatory overlay. This is one reason why aspiring fintech companies may consider foregoing the pursuit of a federal OCC “fintech” charter in favor…
Treasury’s “Unified Regulatory Sandbox” Proposal– Keeping America’s Financial Technology Sector Competitive Will Require Innovation—And Cooperation
By Norman Roos on
Posted in Virtual Currency
In its July 2018 report on “A Financial System that Creates Economic Opportunities,” the U.S. Treasury Department outlined its proposals to identify improvements to the regulatory landscape to “better support nonbank financial institutions, embrace financial technology, and foster innovation.”
The Treasury Report contains over 80 specific recommendations for “Embracing Digitization, Data and Technology,”…