Insights

In our client alert of September 30, 2026,1 we provided an executive summary of federal banking regulators’ Proposed Third-Party Risk Management Guidance (the “Proposal”), a related joint statement on community banks’ engagement with core service providers, and a proposed Federal Reserve guide for traditional community banks (the “Community Bank Guide”).2 This blog post covers what these agency pronouncements mean for fintechs and the banks that sponsor their programs.

On September 2, 2026, the Federal Reserve, FDIC, NCUA, OCC, and FinCEN confirmed that a bank may tell a customer that an account restriction or closure, or a rejected deposit, may be related to suspected fraud or other suspicious activity, so long as the communication does not reveal that a SAR was or will be filed.

Paul Muscutt was recently quoted in Car Dealer Magazine UK in an article covering the collapse of car finance litigation funder Woodville Consultants in a £330 million bankruptcy.

Cristina Diaz was recently featured in an in-depth Corporate Counsel Q&A that covers her return to private practice after more than a decade in-house at UBS.

Register now to join Crowell partners Joanna Forster, Toni Michelle Jackson, and Daniel Leff for a focused discussion on surveillance pricing — what it means for your business, the risks it creates, and the concrete steps you can take now, from reviewing your pricing practices and privacy policies to building a proactive risk management strategy. The webinar will take place on Wednesday, June 10, 2026 from 12:30 – 1:30 p.m. EDT.

Much has been made in the legal press and elsewhere following litigation funder Burford Capital’s announcement of its intention to purchase minority stakes in U.S. law firms. Since, except in a few specific U.S. jurisdictions, legal ethical rules prohibit actual ownership of law firms by non-lawyers, Burford was apparently referring to a structure known as “Management Service Organizations” or MSOs. The MSO structure for law firms entails a law firm essentially splitting into two parts: one part being the legal service providing, client-facing portion and the other part being the MSO, which will take over all other law firm functions: administration, accounting, technology, recruiting, HR, real estate, etc. – anything not directly related to the practice of law. As with any other vendor, the MSO is paid a fee for providing these services.

London – September 11, 2025: Tom Dell’Avvocato has joined Crowell & Moring U.K. LLP as a partner in its Financial Services Group. Dell’Avvocato brings extensive experience in non-contentious banking and finance transactions, with a focus on domestic and cross-border asset-based lending, as well as leveraged and specialty finance. He advises alternative and private capital providers, bank and non-bank lenders, and corporate borrowers on the structuring, restructuring, and execution of complex financing arrangements.