Matt Profile picture
Legal nerd and GC @lithic - Former Stripe, SQ, BlueVine, MoFo, Cap One. Views are mine, and not my company's. But have you heard of https://t.co/KEFRkntP7G?
Jeremy Cai Profile picture 1 added to My Authors
20 Jul
It’s a win for @Marqeta that @Square launched it’s checking account product at Sutton vs. Square Financial Services (the ILC). Should mean all that new debit card volume runs over the $MQ processing stack.
The Square team is super sharp, so I assume they negotiated for an exclusive ABA routing number for the checking account product. This + a contractual right to move the ABA BIN would allow them to migrate the ABA routing number without having to reissue checks.
And assuming they negotiated to remove the issuer name from the physical card, they can move the debit BIN to their own ILC without having to reissue cards.
Read 4 tweets
25 Apr
One of my favorite weekly FinTech newsletters made the claim that Stripe invented the PayFac category. The newsletter is a fantastic regular read, but this claim isn't true. Here's some background on the history of PayFac from someone who lived it.

1/
2/ But first, how great is Privacy.com - 12 free cards a month, pay for other bells and whistles, always keep your online shopping safe.

And we're hiring. Stop reading about FinTech history and come create it with me, @bolingj, @CharlieKroll and all the others.
3/ So back to PayFac.

The term actually used to be called Payment Service Provider or "PSP." Here's a screenshot from a 2017 Visa product guide with some references to the old term.
Read 13 tweets
25 Mar
FinCEN's been busy cooking up new policies, rules and initiatives, so wanted to share some things I've found interesting.

Read on for more about what FinCEN is doing with NFTs, the forthcoming Fin Crimes Tech Symposium, and what's up with the new AML law from 2020. 1/
As background for you noobs, FinCEN is the Financial Crimes Enforcement Network. It's my favorite network (sorry CNBC), and technically a division of the U.S. Treasury department. They make and enforce federal AML rules. 2/
With background out of the way, we can focus on important stuff

Like Privacy.com! The safest and easiest way to pay. 12 free cards a month, and pay for other features.

Really like us? We're hiring! Engineers, Designers, and whatever Role Meghan Markle Wants! 3/
Read 25 tweets
30 Dec 20
Ohad asks a good question. I'm on hold with Wells Fargo checking refinancing options. So let's do a quick thread.
2/ First some background. Synchrony Financial, who issues the Venmo credit card, was issued an approval order for a novel credit card product.
3/ (My former colleagues should pay attention, as some frequently mis-use the term "secured credit")

Synchrony wants to offer cards that start as secured credit. Cardholders can then graduate to an unsecured credit card account after 12 months of good payment history/use.
Read 31 tweets
28 Dec 20
This is actually the hardest part for lawyers transitioning from law firm or government life to in-house counsel roles. Those other experiences train you that being “right” is the most important thing. Being in-house counsel, you learn that outcomes are the most important.
This isn’t to say that in-house counsel need to enable law breaking or non-compliance. It’s about navigating the grey.
Law firm and government lawyers tend to be trained and rewarded for strong arming their audience. But if you do that repeatedly as in-house counsel, you lose your credibility and people try to work around you.
Read 8 tweets
24 Dec 20
1/ Gather round all, from near and from far. This is the tale of the SAR on the Car.
2/ Our tale begins with an electronic transaction. For $9,999 marked “for the car, in full satisfaction.”
3/ While this small note may seem fair by itself, it still caught the eye of one Alice P. Welch.
Read 47 tweets
1 Dec 20
1/ Today the U.S. Consumer Financial Protection Bureau (“CFPB”) issued an advisory opinion about earned wage access products. If you’ve wondered what the legal skinny is on Dave, Earnin, Even and all the others -- this thread is for you.

files.consumerfinance.gov/f/documents/cf…
2/ But first a word about Privacy.com. The safest and easiest way to shop online. Holiday deals are here :) So are hackers :(

Keep your bank card safe. Use Privacy cards instead. Free to use, easy to sign up.

And neobank builders will love our APIs and docs.
3/ Back to earned wage access.

Lots of FinTech cos will give you early access to your wages. Some front ACH while the credit clears. Others give you money by the day, up to several times a month.
Read 38 tweets
18 Nov 20
1/ Am listening to the CFPB's consumer advisory committee meeting discussion on the Section 1033 consumer info sharing rule making and current market trends. Some notes and thoughts here.
2/ All the long-time Bureau folks seem to be here. Will Wade-Grey presented. Gary Stein is talking now. David Erich, an operator/founder/thought leader on the advisory committee is dialed in. 36 panelists in total. Other attendees listening in are hidden.
3/ For context, Section 1033 of the Dodd Frank Act lets the CFPB write rules to create an open banking regime. There's an open comment period right now. I plan on doing a deep dive in the next week or so and will likely write a comment letter in my capacity as a private citizen.
Read 57 tweets
16 Nov 20
Three year old has been walking around the house for a week talking about how she’s going to “punch Donald Trump in the B-U-T-T.”

Wife is asking her to unpack her plan while taking a bath. Live tweeting it here.
Wife: How are we going to get to DC.

3YO: Daddy will drive me.

Wife: it’s far.

3YO: He’ll drive all night.
Wife: How are you going to get into his house?

3YO: My friend Mila will knock on his door.

Wife: then what?
Read 8 tweets
2 Nov 20
1/ Lots of interesting nuggets on the PayPal earnings call. And Dan Shulman saying "regulators" four times in his opening remarks. Thread following here later tonight (Pacific time).
2/ pre-thread nugget -- after-hours trading going lower the more Dan Schulman and John Rainey talk about Q4 and dodge on 2021 forecasting. Was -$10 a share a few minutes ago. Rainey continues to take Q4 and 2021 forecast questions, and stock going lower (down $12 a share).
3/ @PolicyPitts - you doom scrolling late on the East Coast? Cause I'm back and a tweeting about the @PayPal earnings call.
Read 64 tweets
28 Aug 20
1/ .@alexh_johnson asked if I might weigh in on why the CFPB is requesting info on the U.S. consumer credit card market.

Buckle up for a tale of gun-toting senators, people being angry about mail, slow government regulators and Maxine Waters . . .
2/ First a brief detour --

Folks are angry due to the horrible incident with Jacob Blake. Regardless of how you feel about BLM or democrats, I bet you do have feelings about people.

I bet we can all agree keeping people alive is good, and US people should have the same rights.
3/ Almost done -- if you typically dismiss things like BLM, or raise what-about-isms to confirm your views, why not think differently for a few days? Maybe ask how you’d feel if your neighbors and and people that look like you kept getting shot just for doing normal things.
Read 37 tweets
3 Aug 20
.@noyesclt had a good blog post where he called @Square a potential loser due to @Apple's purchase of @mobeewave

I respectfully disagree with Tom. Square will remain the leader for next gen POS and SMB services. But Fiserv, and Visa and MC may have a new threat. Thread below.
First a story. I saw a demo two years ago where a large online acquirer (think Adyen-like) had someone take a tap payment via their cell phone. No extra hardware.

As a Square shareholder, I almost shit my pants.
I texted a few other folks in payments about what I saw (they had the chance, but missed the demo). We agreed Square would be toast.

Two years later, and Square is still chugging along and growing. So what gives?
Read 37 tweets
28 Jul 20
Glad @mengxilu flagged this. Affirm's rated securitization is a great spring board to chat (type?) about FinTech capital markets, valid-when-made and true lender issues.

Lots of recent developments in this space. Anyone else up for a thread? Then let's read on!
As a baby lawyer, I worked on MSB, CDO and eventually ABS card and auto deals. I was both law firm and in-house counsel. And I dealt with Reg AB, SEC Form ABS-15G reporting and also how to deal with risk retention.
ABS or asset-backed securitization has long been a critical funding tool for non-bank lenders, and even fledgling bank lenders.
Read 52 tweets
22 Jul 20
Okay -- kids are asleep. Dishes are done(ish). Time to break down this super cool AML development for US banks and FinTech. Thread follows this message.
We'll start with a question -- what does every product manager and product-mided ally inside a bank or FinTech hate?
It's "friction." And most product managers in FinTech have come to learn, loathe and then accept the friction that occurs with "know your customer" or KYC (KYB for businesses).
Read 44 tweets