Mr. Douglas is a partner in Davis Polk’s Financial Institutions Group, heading the firm’s bank regulatory practice. [Full Bio]

Vice Chair for Supervision Randal Quarles’ announcement that the Federal Reserve is re-examining its framework for making control determinations under the Bank Holding Company Act is a welcome development.  In critiquing the control framework, which has developed piecemeal over decades, Vice Chair Quarles called it “complex and occasionally opaque” and … Read More

Since the CFPB issued its Arbitration Rule in July, most commentators have focused on ways the rule may be blocked from going into effect. Chief among these is the possibility that Congress will vote to overturn the rule under the Congressional Review Act, and the House did promptly vote in … Read More

In a much-anticipated action, on July 25 the SEC issued a Section 21(a) report of its investigation into an offering of digital tokens by “The DAO,” an unincorporated virtual organization. Though declining to take enforcement action against The DAO, the SEC used the opportunity to warn others engaged in similar … Read More

The OCC’s fintech charter proposal is generating a lot of political and media sound and fury. Comptroller Curry’s speech in strong defense of the fintech charter was followed by a letter from the House Financial Services Committee warning the Comptroller against finalizing the new policy – i.e. beginning to accept … Read More

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Davis Polk and Autonomous Research discuss the OCC’s special-purpose national bank charter and its impact on growth-stage technology companies and financial incumbents. A wide range of business models and investors should understand the potential impact of the new charter. This webcast covers:

  • Pros and
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On December 2, 2016, Comptroller of the Currency Thomas Curry announced the OCC’s proposed framework for granting limited purpose national bank charters to fintechs during an event hosted by Georgetown Law’s Institute of International Economic Law. This announcement follows on the heels of the OCC’s “Responsible Innovation Framework” released in … Read More

In October 2016, the U.S. federal banking agencies jointly issued an advance notice of proposed rulemaking regarding enhanced cyber risk management standards (the “Enhanced Standards”).  The Enhanced Standards would apply on an enterprise-wide basis to large financial institutions and their service providers, as detailed in this memorandum.  The U.S. federal … Read More

In September 2016, the New York State Department of Financial Services (the “NYDFS”) proposed new cybersecurity regulations (the “Proposed Rules”) for banks, insurance companies and other financial institutions regulated by the NYDFS (“Covered Entities”).[1]  The Proposed Rules reflect an ongoing interest in cybersecurity by

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