Karsten Wenzlaff, Advisor
August 26th, 2025
Lewis Brisbois Bisgaard & Smith LLP (via Mondaq) | Thomas Brooks and Jane Luxton | Apr 4, 2020
The term “fintech” is used to describe the application of new technology to improve the delivery and use of financial services and products in a more cost-effective way than is available in the traditional financial marketplace. The fintech industry is growing by leaps and bounds with an explosion of new products and services. While most fintechs are regulated by a variety of state and federal regulators, increasingly fintechs are considering the advantages of regulation by traditional banking authorities, a simplifying approach that consolidates regulatory oversight in one agency.
This emerging trend offers opportunities and potential pitfalls for fintechs and requires careful planning and implementation. However, the Federal Deposit Insurance Corporation (FDIC) took a big step toward providing some clarity for fintechs that are considering this path with its March 17, 2020 “Proposed Rule: Parent Companies of Industrial Banks and Industrial Loan Companies.”
If adopted, this proposal would provide a transparent roadmap for a non-depository financial entity to either acquire an existing industrial loan company (ILC) or to apply for deposit insurance for a newly chartered ILC, ensuring federal regulation by the FDIC.
An ILC is a type of state-chartered bank that is insured by the FDIC, but its parent holding company is statutorily excluded from supervision and regulation by the Federal Reserve Board. ILCs generally have the same lending powers as traditional commercial banks. However, the parent of an ILC has an advantage over traditional banks because it can engage in commercial activities, while the parent of a traditional bank -- a bank holding company regulated by the Federal Reserve -- is prohibited from doing so. Over half of the current ILCs are chartered in Utah, but they also exist in California, Hawaii, Minnesota, and Nevada. No ILCs have been established since 2008, largely due to moratoria imposed by the FDIC and Congress. Now, however, the situation is changing.
An ILC is regulated by one federal entity (the FDIC) and one state regulator that granted its charter. Consolidating regulatory oversight saves time and money by avoiding the need to comply with several state licensing laws and regulations, as banks must do. Also, the ILC does not have to submit to multi-state examinations of its operations. Another significant advantage is that insured deposits provide a much lower cost of funds than other sources of funding. A lower funding cost would still allow reasonable profits, but would make lending more competitive with traditional bank lending rates. A further benefit is that an FDIC insured ILC can rely on interest rates of the state in which it is chartered instead of having to comply with the usury laws of several states.
The purpose of the proposed rule is to codify existing practices utilized by the FDIC to supervise ILCs and their parent companies. It is designed (1) to mitigate undue risk to the FDIC insurance fund that may otherwise be present due to the absence of consolidated supervision of an industrial bank and its parent company, and (2) to ensure that the parent company that owns or controls an industrial bank serves as a source of financial strength for the industrial bank.
For typical state-chartered banks, the FDIC would be the primary federal regulator of the bank and the Federal Reserve would be the primary federal regulator of its parent holding company. Because the Federal Reserve does not regulate the activities of the parent of an ILC, the proposed rule provides that the FDIC, the ILC, and its parent enter into a written agreement to ensure that the ILC and the parent are operating in a safe and sound manner.
The proposed rule requires that written agreements must contain specific elements. However, depending on the type of applicant and its business plan, the elements contained in the agreement can be expanded. These requirements are in addition to the standard information that an ILC applicant for deposit insurance must provide to the FDIC.
The approvals for deposit insurance submitted by Square and Nelnet were implemented under existing FDIC policies and procedures. These were important breakthroughs because for the first time in 12 years, the FDIC approved deposit insurance for ILCs. The FDIC’s move to codify these procedures in the proposed rule means that other fintechs will have clearer guidelines for obtaining the same results, which is an important takeaway.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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Techcrunch | Ann Marie Mehlum, Javier Saade | April 10, 2020
The two of us oversaw the U.S. Small Business Administration’s capital, investment, loan and innovation programs serving America’s small businesses. The nation is rooting for our 30 million small businesses. They employ more than half of the country and create most net new jobs, and 80% of them have less than 60 days cash on hand.
The world has never experienced dislocation of labor and business activity at this scale and speed. We applaud Congress and the White House for stepping up with a $2 trillion relief package, of which, $350 billion is being injected into America’s small businesses. Another $250 billion is being contemplated and negotiated as we write this.
Washington has been talking regularly with the financial sector, and for small business relief to be effective, banks of all sizes, fintechs, other tech companies, community banks and other capital conduits need to be involved in the solution. There is an urgent need to deploy the funds, and technology will be critical to that end.
Good steps for sure, but retrofits always come with limitations at their root.
Looking back to move forward, the crisis of 2008 was in many ways a “dress rehearsal” of what we are experiencing now. While there are some similarities, the pandemic’s massive toll on virtually every sector of the economy is happening simultaneously, as evidenced by the fact that 17 million people have filed for jobless claims.
This 21st century problem requires 21st century solutions, and that requires fresh thinking, from policy-to-execution. The large part of our economy that lives at the intersection of small business and the financial system is expecting this thinking and execution.
It must be pointed out that some constraints and limitations of implementing the CARES Act are not regulatory in nature — they are born out of legacy technologies that slow banks down. The antiquated systems of our government agencies, such as SBA’s much talked about and clunky E-Tran system, do not help either.
The financial system has significant tech adoption lags, organizational inertia and regulatory constraints — all contributing to the chaotic nature of the programs’ implementation. The design of a potential fourth phase of relief should take this into account. While pumping more money into small businesses is a good decision, the process and its underpinning needs to be improved.
Probably more important for people to understand is that when banks secure loan guarantees, that does not immediately translate to funded loans injecting cash into small businesses.
This is important because SBA has been tasked to increase its capacity by a factor of at least 50. All of its credit programs combined put out $25 billion a year. The task at hand: $350 billion in 8-12 weeks. We know SBA has been working 24×7 — along with Treasury, FRB and other agencies — on systems, technology and execution, but there are real friction points working against solving the problem at hand.
The use of digital constructs and 21st century technology is highly needed due to the amount of dollars, number of loans and the short window we have to deploy them. We urge the SBA, other agencies and regulators to deploy energy and resources to leverage digital finance and financial technology.
Financial technology can help streamline applications, comply with know-your-customer and anti-money laundering rules and application automation. Technology also improves origination, underwriting, loan disbursement and loan servicing, and should be leveraged. Millions of small businesses, the most vulnerable ones in fact, don’t use bank credit. Yet many use Square to accept payments, for example. Fintech now has an open door to participate — good!
We encourage regulators to fully leverage the collective capabilities of technology.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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Medium | Victoria Bennett | March 18, 2020

This week has seen considerable changes in the world, from markets falling, oil prices falling, schools closed, borders closed. We’re moving into a new world order, and this isn’t for a week or two. How can your business stay healthy and grow?
Your company needs to prepare for this new world order. Firstly, look at spending and consider how you can reduce your burn rate? Look at your revenues. What will this ever-changing world do to your revenues? If some taps are turned off, how can you reposition your company to access new revenue streams? Government stimulus funding may help you to access the new revenue streams or pivot.
It’s not all doom and gloom. The 2008–2009 recession founded Uber, AirBnB and Slack, disruptive businesses that took the opportunities in the market. Other companies grew through acquisition and benefited from cheaper assets.
Most outside money, such as Angel Investors or VCs, requires kissing many frogs. You have to meet a large number of people, typically face to face, to build understanding, trust and secure funding.
Last week our company was due to host three investor events. The first one on Tuesday, had over fifty people in Vancouver, the second on Wednesday twenty in Calgary. Then the third back in Vancouver had to be cancelled as the venue went on COVID-19 lockdown. With Social Distancing measures, traditional fundraising needs to be turned on its head.
Crowdfunding may be the solution to raise capital from a large number of investors across the whole country without meeting them face to face. The whole process takes place online, from reviewing the offering documents, signing and paying. It can all take place without any face to face interaction. That provides social distance for the investor, the company’s employees and lawyers.
Crowdfunding works best where you can tell a story because people like to back what they believe in, and that is certainly the case for retail investors. For larger investors, they are often looking for deal flow. A crowdfunding platform can provide both. The video gives you a chance to see the team, and to understand their why? The “why” is vital because that motivates companies through the bad times as well as the good.
It is important to tell your story and make it relevant to the current reality, but you need to be authentic too. Next week we are launching an equity crowdfunding campaign for a pain-free needle. The device is pre-dosed and has an enclosed sharp; therefore, it doesn’t require sharps disposal. In the not too distant future, there will be a need to vaccinate a large global population quickly, without fear of pain, or mis-dosing or sharps disposal in developing countries, and at a similar price to a syringe and vial of the drug. PKA SoftTouch, who developed the device, has a story that is natural and resonates in the current landscape.
It is noisy out there; social media feeds are full of COVID-19 advice and emails acknowledging that every company you have ever dealt with has a COVID-19 policy. This too will pass. Advertising spend is already decreasing. With potential drops in revenue, this does make sense, but the companies that responded best after 2008 were the companies that remained in the market and continued to tell their stories. If you are crowdfunding, it will be easier to get your story out, as you will be competing with fewer companies and lower overall marketing spend.
We are social creatures; working from home, we may look to other ways to stay connected. Business channels such as Slack, LinkedIn and Zoom and social channels such as Instagram and Facebook will be our source of connection. These are the main outreach channels for crowdfunding. The increase in working from home means potential investors could have more time without the daily commute and be online more, as well.
A webinar will replace the events cancelled on Thursday and this Tuesday. Potential investors have the opportunity to ask questions and gain trust and understanding so that they can move forward to invest. A face to face launch event scheduled the following week will be live-streamed. This will allow a small group from the company to be present and the larger group of interested investors to meet the team and hear the key information.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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American Banker | Kevin Wack | March 12, 2020
The latest high-level hire at Social Finance is a former Jeff Bezos deputy who will oversee the San Francisco firm’s deposit, credit card and brokerage units.
Maria Renz, who spent 21 years at Amazon, joined SoFi on Wednesday as an executive vice president and group business unit leader. She reports to CEO Anthony Noto, who joined SoFi in 2018 from Twitter.
The hiring shows how much emphasis SoFi, which has been building out its menu of financial products, is putting on operations and customer experience.
Renz has no previous experience in financial services, but she does have an extensive background in consumer-facing businesses that have operational complexities. She joined Seattle-based Amazon in 1999, rising through the e-commerce giant’s ranks and eventually leading a team of 80,000 employees who provide customer service around the globe.
The three SoFi business-unit leaders who now report to Renz all have backgrounds in the financial services industry. Eugenia Gibbons, who heads SoFi Money, the company’s cash management account, is a former BBVA executive.
John Gardner, who leads SoFi’s investment, insurance and advisory unit, was previously a co-founder of the personal finance software firm LearnVest and chief operating officer at Cabezon Capital Management.
And Naga Parvatharajan, who heads SoFi’s credit card unit, formerly worked in Goldman Sachs’ consumer banking division. SoFi’s foray into the credit card business is expected to launch later this year in partnership with Mastercard.
TechCrunch | Romain Dillet | March 12, 2020
Fintech startup Revolut has introduced a new trading feature for premium users. Starting today, Premium and Metal users can access gold exposure from the app.
Revolut works with a gold services partner (London Bullion Market Association) so that money you spend on gold exposure is backed by real gold held by this partner. In other words, you’re not going to receive gold coins in the mail. You can just invest money based on the price of gold.
The startup has been building a financial hub and already lets you purchase cryptocurrencies and buy public shares. Gold is part of a new feature called Commodities.
There are multiple ways to invest in gold. You can purchase gold exposure directly at market price, set a limit price to auto-exchange gold when it reaches a certain price or get cashback in gold for Metal customers.
At any time, you can convert your gold investment back into fiat currencies or cryptocurrencies. If you spend money with your Revolut card and you only have gold, Revolut will use your gold exposure automatically. You can also transfer gold exposure to another Revolut user.
According to the company’s website, Revolut charges a 0.25% markup when you trade gold during the week and a 1% markup from Saturday at midnight to Monday at midnight U.K. time.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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CSA| Release | Feb 27, 2020
The Canadian Securities Administrators (CSA) is seeking comment on proposed harmonized rules for start-up securities crowdfunding.Proposed National Instrument 45-110 Start-up Crowdfunding Registration and Prospectus Exemptions would replace and enhance the requirements currently in effect in British Columbia, Alberta, Saskatchewan, Manitoba, Québec, New Brunswick and Nova Scotia.
Enhancements from the current requirements include:
“Small businesses and start-ups need unified regulatory requirements for securities crowdfunding to expand their access to capital,” said Louis Morisset, Chair of the CSA and President and CEO of the Autorité des marchés financiers. “This proposed National Instrument would introduce a single, harmonized set of rules, and increase the thresholds for capital-raising and investing, while still providing appropriate investor protection.”
Since 2015, about 70 distributions of securities have taken place under the existing start-up crowdfunding prospectus exemptions, with an average investment of $734 from each purchaser.
The notice and request for comment can be found on CSA members’ websites. Stakeholders are invited to submit their comments in writing by May 27, 2020.
The CSA, the council of the securities regulators of Canada’s provinces and territories, co-ordinates and harmonizes regulation for the Canadian capital markets.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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