Supervisory Policy & Guidance

This memorandum reviews two issuances released by the federal banking agencies (the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency, jointly the “Agencies”) related to bank-fintech partnerships: (1) a supervisory guidance (the “Guidance”) on banking-as-a-service (“BaaS”) arrangements; and (2) a request for information on bank-fintech arrangements involving banking products and services distributed to consumers and businesses (the “RFI”). Comments on the RFI are due 60 days after publication in the Federal Register, and the...

We provide comprehensive legal counsel to banks ranging from community institutions to the largest national and regional banks, as well as specialized trust, wealth management, and employee benefits institutions. Our services span regulatory compliance and examination support, licensing and charter applications, M&A transactions, and public policy advocacy before Congress and federal banking regulators. Capital Analysis: We assess treatment of assets, instruments, and transactions under bank or GSE capital rules. Consumer Compliance: We assist clients with compliance matters on a variety of...

Nancy Worth specializes in matters involving the federal financial regulatory agencies, with a particular focus on federal consumer law and fair lending. She advises on supervision and compliance matters relating to mortgages, credit cards, and other lending products, and on examination guidance, applications, reports of examination, enforcement actions, and consumer complaints. Her practice extends to commenting on agency review of legislation and Consumer Financial Protection Bureau regulations. Nancy previously served as Special Counsel for the Office of the Comptroller of the Currency...