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The Financial Crimes Enforcement Network (FinCEN) and the Federal Reserve Board (together the Agencies) last week proposed amendments (the Proposed Rules) to the Travel Rule regulations and related Recordkeeping Rules under the Bank Secrecy Act (together the Rules).[1]

Lowering the threshold for cross-border transfers…
Continue Reading FinCEN and the Federal Reserve Board Propose Travel Rule Amendments to Lower the Threshold for Cross-Border Transfers and to Explicitly Cover Convertible Virtual Currencies and Digital Money

The OCC has issued an interpretive letter confirming that national banks may take deposits that serve as reserves for fiat currency-pegged stablecoins.  The letter continues the series of actions taken or announced by Acting Comptroller Brian Brooks to clarify how traditional banking regulations apply to fintech activities—particularly when those activities…
Continue Reading OCC Confirms that National Banks May Take Deposits that Serve as Reserves for Fiat-Pegged Stablecoins

Our memo delivers key takeaways on the Federal Reserve’s recent announcement about its research into central bank digital currency, along with some useful resources. We also place the Federal Reserve’s recent announcement, in a speech by Governor Lael Brainard, in the overall international context.

Please read our client memorandum for…
Continue Reading The Federal Reserve And Central Bank Digital Currencies

As Acting Comptroller Brian Brooks promised in his Statement on Becoming Acting Comptroller, the OCC proposed a rule on July 20, 2020, setting forth standards for determining the true lender of a loan made in the context of a partnership between a national bank or federal savings association (…
Continue Reading The OCC Proposes Two Standards for the True Lender Question

On April 20, 2020, the UK Chancellor, Rishi Sunak announced a new £500 million scheme (delivered by the UK Government in partnership with the British Business Bank) to provide convertible loans (alongside private third party matched investors) as bridge funding to innovative companies facing financial difficulties due to the coronavirus…
Continue Reading UK Announces £500 Million Convertible Loan Scheme for UK Start-ups Hit By Coronavirus (COVID-19)

The FDIC proposed a rule to formalize certain longstanding expectations it has for approving applications by new industrial loan companies (ILCs) that would be subsidiaries of a parent company that would not be subject to consolidated supervision by the Federal Reserve. The proposal would require a written agreement…
Continue Reading Client Memorandum: FDIC Proposes Supervision of ILC Holding Companies

In a step forward for the digital transformation of banking and partnerships between banks and FinTechs, the FDIC released proposed changes to its brokered deposit regulations in late December 2019. The proposed changes are designed to update the regulatory framework as much as possible within the constraints of the existing…
Continue Reading Encouraging Innovation: Brokered Deposits—What Fintechs Need to Know to Partner with Banks under the FDIC’s Proposed Regulations

Financial services regulatory reform will continue to be active in 2020, with developments percolating in all three branches of government.  As we observe the changing landscape, here is the 2020 Vision Edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas,…
Continue Reading Davis Polk Financial Services Regulatory Reform Tool—2020 Vision Edition

Building upon its BitLicense regime instituted in 2015, the New York State Department of Financial Services (NYDFS) has proposed two mechanisms by which entities that hold BitLicenses or trust charters with virtual currency authority (VC Licensees) may list or provide other approved services in a…
Continue Reading NYDFS Proposes a Streamlined Approval Process for Services in New Virtual Currencies