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Regulatory Developments in the FinTech Space
7 October 2016
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The Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”) recently released new regulatory guidance and a proposed rule, respectively, which may impact marketplace lending (“MPL”) arrangements and FinTech firms more generally.
The FDIC’s Proposed Examination Guidance for Third Party Lending (“Guidance”) reflects enhanced scrutiny by the agency of the third-party lending model, often seen in MPL arrangements. MPL firms should consider their current arrangements with institution partners to assess whether they may be impacted by the Guidance.
The OCC’s proposed rule would adopt a receivership framework for uninsured national banks. The proposal, if adopted, would lay the groundwork for a potential OCC FinTech charter by which financial innovation may be incorporated into the traditional banking model.
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