Photo of Sarah Hanna

Sarah is an associate in the firm’s Corporate practice. She works with public and private companies on a wide range of corporate matters, including equity and debt offerings, SEC reporting, corporate governance, and financial services matters.

In this crossover episode of The Consumer Finance Podcast and Payments Pros, Taylor Gess is joined by colleagues James Stevens and Sarah Hanna from Troutman Pepper Locke’s Corporate and Consumer Financial Services practices to discuss the surge of interest among fintech and point-of-sale finance companies in obtaining bank charters, acquiring existing banks, and forming bank partnerships. With the current administration signaling an open-for-business posture at the federal banking agencies, and the Office of the Comptroller of the Currency (OCC) actively encouraging de novo applications, payment and fintech companies are weighing their options more seriously than they have in years. The conversation covers what is driving the spike in charter applications, including from companies in the crypto, lending, and payments spaces, and how specialty charters are factoring into that trend. James and Sarah also walk through the bank partnership landscape, where enforcement activity has cooled and focus has shifted, and explain how acquiring an existing bank charter compares to starting from scratch on timing, cost, and regulatory complexity. The episode closes with practical guidance for point-of-sale finance companies considering any of these three paths, including why building internal compliance infrastructure early, engaging regulators informally, and retaining regulatory counsel sooner rather than later can make or break a successful launch.

On October 27, the Federal Trade Commission (FTC) announced a final rule (Final Rule), amending the Standards for Safeguarding Customer Information (Safeguards Rule) under the Gramm-Leach-Bliley Act (GLBA) as it applies to covered financial institutions. The Final Rule provides guidance on developing and implementing information security programs, such as access controls, authentication, and encryption. Notably,

According to a recent announcement, Mastercard will begin providing customers with additional details about their purchases, such as the merchant’s name, logo, and location of purchase. Mastercard is inviting merchants to upload their logos to Ethoca, after which the logos will be linked to the corresponding transaction in digital banking applications. The service