Michael Nonaka is a partner in the firm’s Financial Institutions practice group. He represents banks and other financial institutions on a wide variety of bank regulatory, enforcement, legislative and policy issues. Mr. Nonaka also is co-chair of the firm’s Fintech Initiative and works with a number of banks, lending companies, money transmitters, payments firms, technology companies, and service providers on innovative technologies such as big data, blockchain and related technologies, bitcoin and other virtual currencies, same day payments, and online lending.
On December 2, 2016, Comptroller of the Currency Thomas J. Curry announced that the Office of the Comptroller of the Currency (“OCC”) would move forward with issuing special purpose national bank charters to financial technology (“fintech”) companies. The OCC released a whitepaper outlining its authority to issue charters to fintech companies, its approach to supervising … Continue Reading
Comptroller Curry just announced that the OCC will move forward with issuing limited purpose national bank charters to fintech companies. The OCC’s white paper on the charter concept is available here. We will be circulating a client alert summarizing the white paper shortly.… Continue Reading
The transition to a new administration with the election of Republican Donald J. Trump as President, along with continued Republican control of the Senate and House of Representatives, promises to bring substantial change to each of the federal financial regulatory agencies. Changes in leadership at the federal financial regulatory agencies will likely result in substantial … Continue Reading
President-Elect Donald J. Trump has said little about his plans for money laundering and terrorist financing enforcement, or his plans for the agency responsible for many of the Federal government’s anti-money laundering (“AML”) initiatives, the Financial Crimes Enforcement Network (“FinCEN”). FinCEN is a bureau within the Treasury Department and not a fully independent agency. Its … Continue Reading
On October 25, 2016, OCC Comptroller of the Currency Thomas J. Curry delivered remarks to a group of bank regulators at the tenth annual FDIC Accounting and Auditing Conference. The remarks, addressing the importance of interagency collaboration, provide insight into how Comptroller Curry views the OCC’s relations with the other banking agencies. In his remarks, … Continue Reading
On October 19, 2016, the Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency, and Federal Deposit Insurance Corporation released a joint Advance Notice of Proposed Rulemaking (ANPR) requesting public comment on enhanced cybersecurity standards that would apply to certain large, interconnected financial entities as well as the third … Continue Reading
Earlier today, Federal Reserve Governor Lael Brainard gave a speech at the annual meeting of the Institute of International Finance on distributed ledger technology. She noted that the Federal Reserve has created a working group to conduct a 360-degree analysis of financial innovation, including the impact that distributed ledger technologies may have on payment, clearing, … Continue Reading