Mr. Guynn is head of Davis Polk’s Financial Institutions Group. [Full Bio]

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 Office of the Comptroller of the Currency (OCC) has granted conditional approval to digital-banking startup Varo Bank (previously Varo Money) of its application to form a de novo national bank.  Varo Bank, N.A. would become the first mobile-only national bank in United States. This is an interesting
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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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The Federal Reserve’s current approach to determining whether a banking organization has control over another company for purposes of the Bank Holding Company Act can discourage fintech investments by banking organizations.  This impact was discussed in the Treasury Department’s report on nonbank financial institutions, fintech and innovation.  The report highlights
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The OCC’s announcement that it will begin accepting applications for nondeposit fintech charters is an important and welcome development, especially in light of the Treasury’s explicit support for the nondeposit fintech charter and responsible innovation. The OCC described the fintech charter as allowing fintech companies to acquire or obtain
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