Hey all, Jason here.
You’re getting this slightly later than normal, due to travel and some last minute copy edits (please forgive any typos!). My time in Mexico City was, as always, delightful. I’m already here in Las Vegas for Money2020 — if you’re attending, I hope to see you around the Venetian!
Partner content: Day one: A software platform launches payments for its first customers. Each customer gets their own named U.S. account. Money comes in over ACH or wire, and goes out over ACH, wire, or check.
Year two: Ten thousand customers, now with instant payouts over RTP, FedNow, and push-to-card.
Same setup: one account per customer, one ledger tracking every dollar.
The team stayed focused on their roadmap. Their payments stack scaled with them.
Modern Treasury is the payments platform for accounts and money movement, across fiat and stablecoins, through one API.
Trusted by Procore, Navan, and companies of all sizes. Powering $600B+ in payments.
The Office of the Comptroller of the Currency released its “debanking” report last week.
President Trump’s Executive Order 14331, “Guaranteeing Fair Banking for All Americans,” directed federal banking regulators, including the OCC — ostensibly an independent bureau of the Department of the Treasury — to undertake a review of financial institutions under its jurisdiction that “have had any past or current, formal or informal, policies or practices that require, encourage, or otherwise influence such financial institution to engage in politicized or unlawful debanking and to take appropriate remedial action.”
E.O. 14331 defines “politicized or unlawful debanking” as “an act by a bank, savings association, credit union, or other financial services provider to directly or indirectly adversely restrict access to, or adversely modify the conditions of, accounts, loans, or other banking products or financial services of any customer or potential customer on the basis of the customer’s or potential customer’s political or religious beliefs, or on the basis of the customer’s or potential customer’s lawful business activities that the financial service provider disagrees with or disfavors for political reasons.”
The concept of “politicized or unlawful debanking” is, itself, legally problematic; as Adam Levitin notes in his analysis of the debanking report, “Viewpoint discrimination is entirely legal. No law prohibits banks from engaging in viewpoint discrimination, and there would be 1st Amendment questions about any law that purported to do so.”
The OCC’s supervisory review and subsequent report looked at the alleged debanking activities of the nine largest OCC-chartered banks: JPMorgan Chase Bank, Bank of America, Citibank, Wells Fargo Bank, U.S. Bank, Capital One, PNC Bank, TD Bank, and BMO Bank.
The report can only reasonably be read as a political and an explicitly partisan document; the first sentence of the report…
Read More: Debanking, Reputation Risk, AML, Oh My!
