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A rule by any other name: What is a ‘rule’ subject to disapproval under the Congressional Review Act?

Greg Omer January 17, 2018
confusing arrows with one clear arrow

In addition to formal regulations, informal federal regulatory guidance has become commonplace in the world of banking law. However, the federal Government Accountability Office has recently issued two opinions that could impact this steady flow of informal bank regulatory guidance. READ MORE

OCC’s call for study of separation of banking and commerce: revisited topic with a new twist

Greg Omer November 10, 2017

Whether out of apprehension over a Walmart bank or a Google or Amazon bank, many community banks share a strong concern that commercial firms owning banks would be able to compete for community bank business on unfair terms. READ MORE

Private family trust companies authorized under new Missouri law


The new Missouri Family Trust Company Act allows families to establish their own family-owned and controlled private trust companies, which can hire banks and public trust companies to assist with investment and management functions. READ MORE

State-chartered fintech banking and financial services: What solutions will states pursue?

Greg Omer May 12, 2017

Certain states are now looking into solutions to address the heavy burden of this 50-state regulatory regime on state-chartered banks and state-licensed fintech companies. READ MORE

OCC won’t allow fintech national bank charters for commercial firms, addressing potential Walmart fintech bank concerns

Greg Omer March 17, 2017

The primary concern of many community bankers with allowing nonbank commercial companies to own banks is the potential for the “anti-competitive effects and undesirable concentrations of economic power” referred to by the OCC, which apparently shares that concern. READ MORE

President Trump’s call to ‘rationalize’ federal financial regulation could impact U.S. dual banking system

Greg Omer February 13, 2017
President Trump

One of President Trump’s executive orders included a directive to “rationalize the Federal financial regulatory framework,” which could impact the country’s dual banking system and regulatory options for state-charted banks. READ MORE

Fintech: Internet banking across state borders triggers compliance challenges for state banks

Greg Omer January 20, 2017

State-chartered banks offering financial products via the Internet to out-of-state customers, either directly or through a nonbank fintech arrangement, should be careful to consider the potential compliance pitfalls of the applicable laws of the customer’s home state. READ MORE

Dodd Frank under attack: Which parts will bankers push to keep?

Greg Omer January 10, 2017
illustration of a hand stopping a punch

The Trump Administration may be interested in the “repeal” of the Dodd Frank Act, but are there provisions the banking industry might want to retain - provisions that are actually considered to be beneficial to the banking industry? READ MORE