Bank Service Providers

On September 11, 2026, the Agencies (FDIC, OCC, FRB, and NCUA) proposed interagency third-party risk management (TPRM) guidance (Proposed Guidance), which, if finalized, would replace the 2023 Interagency Guidance on Third-Party Relationships: Risk Management (2023 Guidance). Comments are due November 16, 2026. Separately, the FRB proposed TPRM guide for traditional community banking organizations (FRB Proposal), which is intended to serve as a companion document to the Proposed Guidance. It has the explicit goal of assisting “traditional community banking organizations” (TCBOs) (defined as...

Our fintech work spans regulatory, strategic, and policy engagements for a diverse range of payment ecosystem participants and digital lenders. Our lawyers have experience working with both traditional and innovative institutions, including: retail and commercial payments and lending fintechs (including buy-now-pay-later providers), fintech banks and neobanks, prepaid program managers and issuers, money transmitters, finance companies, crypto and digital asset service providers, payment processors, payment system infrastructure operators, and payments and credit units of technology companies....

BJ Sanford advises payments and fintech companies, U.S. and foreign banks, trade associations, investors, and policy and consulting firms. His practice centers on payments regulation, public policy, and the regulation of bank activities and structure. He also advises clients on regulatory capital, bank investments and control, affiliate transactions, the U.S. operations of foreign banks, and regulatory examinations. Payments regulation. BJ advises payments firms and banks on payment regulation, product development, and compliance with rules including Regulation E, Regulation Z, Regulation II...