June 18, 2019

June 18, 2019

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June 17, 2019

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CSBS Agrees to Implement Recommendations from Fintech Advisory Panel

The Conference of State Bank Supervisors (CSBS) announced last week that it has agreed to implement 14 recommendations made by its Fintech Industry Advisory Panel (Advisory Panel).

The Advisory Panel was formed in 2017 to identify actionable steps for improving state licensing, regulation, and non-depository supervision and for supporting innovation in financial services.  It has 33 fintech company members that engage with the CSBS Emerging Payments and Innovation Task Force and other state regulators.  The Advisory Panel has a subgroup focused on lending and another focused on payments.  Both subgroups submitted reports that formed the basis of the recommendations CSBS has agreed to implement.

Those recommendations primarily address creating uniform definitions and practices, increasing transparency, and expanding the use of common technology among all state regulators.  Among the actions CSBS has agreed to take to implement the recommendations are:

  • Developing a 50-state model law to license money services businesses

  • Creating a standardized call report for consumer finance businesses

  • Building an online database of state licensing and fintech guidance, while encouraging a common standard

  • Developing a new technology offering, a State Examination System, to simplify examinations of nonbanks operating in more than one state

  • Expanding the use of the Nationwide Multistate Licensing System (NMLS) among all state regulators and to all nonbank industries supervised at the state level

At the annual NMLS conference in Orlando, CSBS and the Advisory Panel’s payments subgroup reported that in connection with efforts to harmonize state licensing regimes and ultimately to draft a model state law for licensing money services businesses, CSBS is conducting state surveys relating to existing state definitions and exemptions from licensure and will publish  such surveys when complete.

The CSBS initiative is undoubtedly in part a reaction to the OCC’s decision to grant special purpose national bank charters to fintech companies.  Such charters would eliminate the need for fintech companies to obtain multi-state licenses.  In October 2018, CSBS filed a second lawsuit in D.C. federal district court to stop the OCC from issuing such charters.

Copyright © by Ballard Spahr LLP


About this Author

John Socknat, Partner

John D. Socknat is the Co-Practice Leader of Ballard Spahr's Mortgage Banking Group. John uses his knowledge and breadth of the business issues affecting the residential and commercial mortgage banking industries and the legal landscape to advise clients on compliance and licensing matters under state and federal law.

John's clients include mortgage and consumer finance companies, financial institutions, servicers, collection agencies, title companies, real estate brokers, and secondary-market investors. He focuses his practice in matters...

Stacey Valerio, Of counsel
Of Counsel

Stacey L. Valerio focuses her practice on the mortgage banking industry. Stacey has more than 20 years' experience, including nearly a decade at the State of Connecticut Department of Banking's Consumer Credit Division, where she handled licensing and enforcement matters, with primary focus on the mortgage industry. In that role, she counseled the Consumer Credit Division, served as an administrative hearing officer, and drafted legislation, legal opinions, and rulings. The position also involved working with various other state and federal agencies, including the state Office of the Attorney General, the FBI, and the CFPB. Stacey was active with the State Regulatory Registry LLC's Lawyers Committee for many years, serving as its chair from 2014 to 2017, and was actively involved with the American Association of Residential Mortgage Regulators (AARMR), serving as a director and an officer.

Stacey has experience counseling clients on a wide variety of regulatory matters at the federal and state levels. Her experience includes licensing and regulatory compliance, legislative initiatives, contract drafting, and the Nationwide Multistate Licensing System & Registry (NMLS).


  • George Washington University National Law Center (J.D. 1995)

Member, The George Washington Journal of International Law & Economics

  • University of Pennsylvania (B.A., summa cum laude, 1991)

Phi Beta Kappa

  • Wellesley College (1988-1989)


  • Connecticut
  • Massachusetts
  • District of Columbia
  • U.S. Court of Appeals for the Federal Circuit