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Samer Roshdy

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Samer represents public and private companies on both corporate and financial services regulatory compliance matters. With a significant portion of his practice devoted to representing clients in the financial services industry, Samer routinely advises depository institutions, innovative fintech companies, and other nonbank financial services companies.

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Yesterday, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting potential risks associated with banks’ arrangements with third parties to deliver bank deposit products and services. While the information is not new, it clearly memorializes the issues that have been at the forefront of recent enforcement actions involving banks operating under a Banking-as-a-Service (BaaS) model.

The Federal Deposit Insurance Corporation (FDIC) recently announced a consent order with Tennessee-based Lineage Bank containing orders relating to the bank’s third-party risk management program and its financial technology (fintech) partners.

On January 12, Fiserv announced that it filed an application with the state of Georgia for a merchant acquirer limited purpose bank (MALPB) charter. This application is a seismic development and positive sign for those in the United States pushing for more direct merchant acquirer access to the payment card networks.