Third-Party Risk Management

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 advise banks, fintechs, mortgage companies and others on regulatory compliance across the full spectrum of consumer protection and prudential requirements. Our regulatory practice covers consumer compliance (TILA, RESPA, UDAP/UDAAP, FCRA, HMDA, fair lending), safety and soundness issues, payments rules, and regulatory change management. We help clients understand the impact of new regulations, build compliance programs, and maintain comprehensive regulatory inventories. Services provided by the Regulation & Compliance practice include: Capital Analysis: We assess treatment of assets,...

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...