Category Archives: FinTech

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OCC Addresses Long-Standing Questions on Vendor Management Programs

The Office of the Comptroller of the Currency (OCC) recently issued supplemental guidance (Bulletin 2017-21) on third-party risk management. Responding to questions raised by banks and federal savings associations since the release of the OCC’s Bulletin 2013-19 on vendor management issues, the OCC provided additional insight on topics in the 2013 Bulletin and the application … Continue Reading

The Bank Next Door: Part I – Using Social Media to “Friend” Customers

[This post is the first in a series of post which will examine the risks, rewards, innovative uses, and changing legal landscape of social media use by financial services institutions. Future blog posts will examine topics such as: monitoring and managing consumer complaints through social media, disgruntled employee use of social media, and control over content and message. … Continue Reading

States Oppose OCC’s proposed Fintech Charter

As part of its push to promote innovation in the financial services industry, the Office of the Comptroller of the Currency (“OCC”) plans to allow financial technology (“fintech”) companies to become special purpose national banks. If the proposal is successful, fintech companies could secure a charter providing them with preemptive effects of federal law over … Continue Reading

The Strategic Risk Community Banks May Not Have Considered

Community banks that have not considered the potential for partnership with nonbank financial technology (fintech) companies, alone or in collaboration with other community banks, may not be accounting for the full range of strategic risks to their business. Strategic Risk Defined and Applied In a brief but wide-ranging talk before the Annual Community Bankers Symposium … Continue Reading

Banks Should Prepare for Increased Collaboration between IT, Legal and BSA/AML Compliance Departments under New FinCEN Guidance

Last month, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued an Advisory which provided substantial guidance to financial institutions regarding the scope of information that must be provided in Suspicious Activity Reports (SARs) arising from cyber-events, cyber-enabled crime, and cyber-related information under the Bank Secrecy Act (BSA). When are financial institutions required to … Continue Reading

CFPB Sends Clear Message That FinTech Start-Ups Have Same Obligations as Established Companies

In a clear message to FinTech start-ups, on September 27, 2016, the Consumer Financial Protection Bureau (CFPB) ordered online lender Flurish, Inc. to pay $1.83 million in refunds and a civil penalty of $1.8 million for failing to deliver the promised benefits of its products. Flurish, a San Francisco based company doing business as LendUp, … Continue Reading
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