New York DFS

On July 23, the New York State Department of Financial Services (“DFS”) announced a new Research and Innovation Division.  The Division will assume responsibility for licensing and supervising virtual currencies.  It will also “assess efforts to use technology to address financial exclusion; identify and protect consumer data rights; and encourage innovations in the financial services…

On April 29, 2019 the New York State Department of Financial Services (“DFS”) announced that it has created a new division, called the Consumer Protection and Financial Enforcement Division, which combines the previously separate Enforcement Division and Financial Frauds and Consumer Protection Division.

The new division will be “responsible for protecting and educating consumers and…

On October 25, 2018, the Conference of State Bank Supervisors (“CSBS”) filed a complaint in the United States District Court for the District of Columbia to stop the Office of the Comptroller of the Currency (“OCC”) from issuing special purpose national bank charters to fintech companies.  The lawsuit follows a similar suit against the OCC by the New York State Department of Financial Services (“DFS”) in the United States District Court for the Southern District of New York, which we discussed in September.
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Continue Reading State Regulators Renew OCC Suit Over Fintech Charter

On September 14, 2018, Superintendent of the New York State Department of Financial Services (“NYSDFS”) Maria T. Vullo filed a complaint in federal court against the U.S. Office of the Comptroller of the Currency (“OCC”) to block the OCC from issuing any special purpose national bank (“SPNB”) charters. The OCC announced last month, after much…

With this week’s close of the comment period on the December 2016 whitepaper by the Office of the Comptroller of the Currency (“OCC”) regarding special purpose charters for fintech companies, which we discussed in a previous client alert, several key stakeholders have weighed in on the OCC’s plans.  Notably, on January 13, 2017, the Conference of State Bank Supervisors (“CSBS”), the nationwide organization representing banking regulators from all 50 states, the District of Columbia, Guam, Puerto Rico, and the U.S. Virgin Islands, submitted a comment letter opposing the OCC’s creation of the charter.  On January 17, 2017, the Superintendent of the New York State Department of Financial Services (“NYSDFS”), Maria T. Vullo, submitted a standalone comment letter also opposing the charter.
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Continue Reading State Banking Regulators Oppose OCC Fintech Charter

On October 11, 2016, the New York State Department of Financial Services (“NYDFS”) issued guidance to its regulated banking organizations regarding incentive compensation practices.  The guidance is intended to address recent concerns over compensation practices that may incentivize employees to engage in inappropriate sales practices.
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Continue Reading New York DFS Issues Incentive Compensation Guidance