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.
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.
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.
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/
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.
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.
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.
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.
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.
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.