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Matt Profile picture
Matt
@regulatorynerd
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?
Jul 23 • 15 tweets • 4 min read
1/ I've been getting some good DMs so wanted to break down what could be happening here — 2/ First — there is undeniably tightening in the community bank and fintech sponsor banking space. I have heard solid rumblings that regulators have poked sponsors and told them to slim down the number of programs they have in order to better focus existing staff.
May 25 • 18 tweets • 3 min read
1/ Wanted to share some thoughts on the Synapse issues. Thanks to @mikulaja for all the tracking and glad to see folks like @Hugh_Son and @ddayen help push this news mainstream. 2/ First, the Synapse situation is horrible. Synapse and the banks involved should be locked in a room until they figure out what funds go where and can get funds back to the consumers involved.
Sep 11, 2023 • 29 tweets • 6 min read
1/ If Congress caps credit card interest rates, I think it'll make sense to also revisit the CARD Act to make sure it can facilitate more innovative uses of charge cards and secured cards. 2/ Currently there's some sticking points in TILA and Reg Z that make innovating in charge cards or secured cards difficult. But first, let's recap a few industry practices in the card industry.
Jul 31, 2023 • 45 tweets • 7 min read
1/ I really enjoyed Jason's piece on Laso and the mystery of how a no-KYC card could get approved by Stripe and Celtic.

Before joining Trustly, I lived in the BaaS space for four years and wanted to share some additional insights. 2/ First, as a technical matter, I am going to discuss publicly available information. You can find everything in this thread by looking at various company terms, going on LinkedIn or pulling on general market knowledge about these types of operations.
Mar 10, 2023 • 7 tweets • 2 min read
1/ If you’re a VC or a tech founder with exposure to SVB, it’s good to start talking through contingencies. But it’s also not worth panicking until Monday. 2/ Why Monday?

You’ll get access to insured deposits.

FDIC has said it’ll pay a “dividend” to uninsured deposit customers. I.e., you’ll get access to some uninsured money.

There’s likely to be a sale by Monday, taking uninsured deposits to a new bank so you can access them.
Mar 10, 2023 • 8 tweets • 3 min read
1/ Look—if you're going to doom scroll and react in a tizzy to all the SVB tweets, at least spend some time reading the public portion of their resolution plan.

fdic.gov/resources/reso… 2/ What's a resolution plan? It's something Dodd-Frank mandated for large banks. SVB tripped the trigger in 2021, so now they have to tell the FDIC how they'd be wound down in the event of a large-scale poop show.
Feb 17, 2023 • 6 tweets • 2 min read
1/ Really important point. Pummeling crypto the way the SEC/bank regulators are doing won't protect consumers, and won't let the U.S. reap the innovation benefits of this technology. Policy makers need to get more involved, or risk losing the gains to a different country. 2/ I'm skeptical on crypto as an asset, and tend to agree with @TBakerBroadmoor about how the current product usage smacks of gambling.

But the premise of instant digital transfers, with transparency on A to B, without rent-seeking intermediaries is huge and still likely.
Nov 17, 2022 • 8 tweets • 1 min read
1/ I have questions about this —

American Express - American Express and Square Partner to Create First Credit Card for Square Sellers about.americanexpress.com/newsroom/press… 2/ I love Celtic Bank — they are fantastic partners, but why wouldn’t AmEx or Square’s own ILC be the lender here? This feels inefficient?
Oct 21, 2021 • 67 tweets • 15 min read
1/ The US’s top consumer financial services cop — the CFPB — is requiring several tech giants to turn over information about their payments activities. 2/ but first, have you heard about non-tech Giant privacy.com?

Small but mighty. Up to 12 free cards a month. No interest or late fees.
Jul 20, 2021 • 4 tweets • 2 min read
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.
Apr 25, 2021 • 13 tweets • 6 min read
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.
Mar 25, 2021 • 25 tweets • 7 min read
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/
Dec 30, 2020 • 31 tweets • 6 min read
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.
Dec 28, 2020 • 8 tweets • 2 min read
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.
Dec 24, 2020 • 47 tweets • 9 min read
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.”
Dec 1, 2020 • 38 tweets • 8 min read
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.
Nov 18, 2020 • 57 tweets • 8 min read
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.
Nov 16, 2020 • 8 tweets • 1 min read
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.
Nov 2, 2020 • 64 tweets • 14 min read
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).
Aug 28, 2020 • 37 tweets • 10 min read
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.
Aug 3, 2020 • 37 tweets • 11 min read
.@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.