Margaret E. Tahyar

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Ms. Tahyar is a partner in Davis Polk’s Financial Institutions Group. [Full Bio]

It is no secret that the United States lags behind other countries in the development of a national real-time payments infrastructure.[1]  There are, of course, explanations for this lag, including widespread participation in the existing infrastructure rails and the existence of many different stakeholder interests limiting consensus over reforms. …
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FDIC Chairman Jelena McWilliams has announced a “Trust through Transparency” initiative that is remarkable and well worth a read.  In our view, there are three main takeaways.  One is the importance of transparency to public trust in a Democracy, the second is how important it is that the government be…
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This blog post lays out the pros and cons that boards and senior management of regional and community banking organizations should consider in light of the Zions decision to shed its bank holding company.[1]  Some have suggested that directors of BHCs now have a fiduciary duty to consider shedding…
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Guidance is guidance, and rules are rules.  This straightforward statement was reiterated by Treasury Secretary Mnuchin, Federal Reserve Vice Chairman for Supervision Randal Quarles and Comptroller of the Currency Joseph Otting in separate Congressional hearings earlier this year.[1]  Nevertheless, for at least the past ten years, the failure to…
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The FTC is expanding its enforcement efforts for fintech, particularly in the areas of online and small-business lending, payments, and cryptocurrencies.  At a recent event in Washington, D.C., the FTC’s Director of Consumer Protection, Andrew Smith, stated, “Commissioners are really interested in [fintech].  Finance will be a steady part of…
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The Center for Financial Stability is providing a freely accessible Financial Timeline, curated by Senior Fellow Yubo Wang.  The timeline, created in 2010 and actively maintained, charts more than 1,100 developments across the markets, institutions, the Federal Reserve, Treasury and other sources, from 2007 to the present.  This resource, which…
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The ability of banks to sell the loans they originate is a core element in the development and sustainability of a nationwide lending market.  Recent legal developments threaten to undermine this ability, jeopardizing the foundation of a U.S. nationwide loan market and the core lending activities of banks.

A long-settled…
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The U.S. financial services industry continues to be faced with changes in technology – machine learning, database capabilities, automated process, and innovative products – that change the manner, speed and security with which financial services and products can be provided.  Those of us familiar with the longer term evolution of…
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In its recent report on financial innovation, the U.S. Treasury Department calls upon federal banking regulators to address the uncertainty in lending markets created by the Madden case and True Lender developments.

The Report recognizes that “unsecured consumer credit could be diminished because nonbank firms such as marketplace lenders may…
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