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FinTech Timeline

Traditional Financial Regulation to FinTech Regulation:
A Brief History

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All Other

2024

05.03.2024 – The Federal Reserve Board of Governors, the FDIC, and the OCC issue "Third-Party Risk Management: A Guide for Community Banks." LINK(link is external).

2023

08.08.2023 – The Federal Reserve announces the creation of the Novel Activities Supervision Program, which aims to monitor and examine novel activities, such as crypto-asset related activities and distributed ledger technology, in partnership with existing supervisory teams. LINK(link is external).
06.16.2023 – The Federal Reserve launched the master account and services databases, which lists financial institutions that have access or have requested access to Reserve Bank master accounts and financial services. LINK(link is external).
06.06.2023 – The FDIC, the Federal Reserve, and the OCC issue “Interagency Guidance on Third-Party Relationships: Risk Management.” LINK(link is external).
04.25.2023 – The U.S. Department of the Treasury issued the 2023 De-risking Strategy in relation to the Anti-Money Laundering Act of 2020. LINK(link is external).
02.23.2023 –The Federal Reserve, FDIC, and OCC issue a “Joint Statement on Liquidity Risks to Banking Organizations Resulting from Crypto-Asset Market Vulnerabilities.” LINK(link is external).
01.23.2023 – The New York Department of Financial Services (NYDFS) issues, “Guidance on Custodial Structures for Customer Protection in the Event of Insolvency.” LINK(link is external)
01.03.2023 – The Federal Reserve Board of Governors, the FDIC, and the OCC issue a "Joint Statement on Crypto-Asset Risks to Banking Organizations." LINK(link is external).

2022

10.03.2022 – The Financial Stability Oversight Council (FSOC) releases the “Report on Digital Asset Financial Stability Risks and Regulation.” LINK(link is external).
08.19.2022 – The FDIC issues five Cease and Desist letters to companies making crypto-related false or misleading representations regarding deposit insurance. LINK(link is external).
08.16.2022 – The Federal Reserve Board of Governors issues “SR 22-6 / CA 22-6: Engagement in Crypto-Asset-Related Activities by Federal Reserve-Supervised Banking Organizations” clarifying expectations for Federal Reserve supervised institutions that are engaging in crypto-related activities. LINK(link is external).
08.15.2022 –The Federal Reserve Board of Governors announces Final Guidance that establishes a set of factors when requests are made to access the Federal Reserve payment system. LINK(link is external).
07.29.2022 – The FDIC publishes “Fact Sheet: What the Public Needs to Know about FDIC Deposit Insurance and Crypto Companies,” which is intended to address common and emerging misconceptions about FDIC insurance coverage. LINK.
05.25.2022 - NCUA issues a letter to Federally Insured Credit Unions (FICUs) clarifying expectations for FICUs contemplating the use of new or emerging distributed ledger technologies (DLT). LINK(link is external).
4.07.2022 – The FDIC issues FIL-16-2022 stating that all FDIC-supervised banks must notify the FDIC of any crypto or digital asset activities. LINK(link is external).
3.09.2022 – President Biden issues Executive Order 14067 on digital asset regulation entitled, “Ensuring Responsible Development of Digital Assets.” LINK(link is external).
1.20.2022 – The Federal Reserve issues report, “Money and Payments: The U.S. Dollar in the Age of Digital Transformation.” The report discusses the uses, benefits, and risks of issuing a Central Bank Digital Currency (CBDC). LINK(link is external).

2021

12.16.2021 – NCUA issues a letter to Federally Insured Credit Unions (FICUs) allowing FICUs to establish relationships with third party vendors that engage in digital asset and cryptocurrency services, subject to certain conditions. LINK(link is external).
12.02.2021 - SEC Chair Gensler makes advisory statements that cryptocurrency tokens are likely securities that need to be registered with the SEC (or meet an exemption), and that cryptocurrency trading platforms likely need to be registered with the SEC. LINK(link is external).
11.23.2021 – The Federal Reserve, FDIC, and OCC issue a Joint Statement on Crypto-Asset Policy Sprint Initiative and Next Steps. LINK(link is external).
11.17.2021 – The OCC issues Interpretive Letter #1179, which requires national banks to obtain supervisory non-objection(s) from the OCC when engaging in cryptocurrency activities. The letter also clarifies and reaffirms the OCC’s stance on former interpretive letters regarding cryptocurrency. LINK(link is external).
11.01.2021 - The Biden Administration issues a report on stablecoins calling for 1) stablecoin issuers to be regulated like banks, 2) stablecoin wallets to be regulated like banks, and 3) stablecoins to be kept separate from commercial activity. Input on the report was provided by the U.S. Treasury, the Board of Governors of the Federal Reserve System, SEC, CFTC, FDIC, and the OCC. LINK(link is external).
10.29.2021 - The Financial Action Task Force (FATF), a global inter-governmental body, issued updates to its guidance on Virtual Asset Service Providers. LINK(link is external).
10.06.21 – The U.S. Justice Department announces a national cryptocurrency enforcement team. LINK(link is external).

2020

12.17.20 – LabCFTC issues a primer for digital assets. LINK(link is external).
11.17.20 – The SEC issues a No Action Letter for IMVU, Inc. LINK(link is external).
11.9.20 - SEC Staff Statement on the Wyoming Division of Banking’s No-Action Letter. LINK(link is external).
10.23.20 - The Wyoming Division of Banking issues a No Action Letter stating that a state-chartered trust company may act as a qualified custodian under the Investment Advisers Act of 1940. LINK(link is external).
9.21.20 - The SEC FinHub issues a statement on the Securities and Exchange Commission (SEC) interpretation addressing the authority of national banks and federal savings associations to hold stablecoin reserves. It reiterated that whether a particular digital asset, including one labeled as a stablecoin, is a security under the federal securities laws is a facts and circumstances determination. LINK(link is external).
7.22.20 – The OCC announces that federally chartered banks and thrifts may provide custody service for crypto assets. LINK(link is external).
6.24.20 – The CFTC issues final interpretive guidance on the term “actual delivery” for digital assets. LINK(link is external).
1.14.20 – The SEC publishes an investor bulletin on Initial Exchange Offerings (IEOs). LINK(link is external).

2019

10.28.19 - The SEC issues No Action Letter for Paxos Trust Company, LLC. LINK(link is external).
10.11.19 – SEC, CFTC, and FinCEN issue a joint statement on digital assets. LINK(link is external).
10.1.2019 – The Wyoming Special Purpose Depository Institutions Act (SPDI) is effective. The law creates a Wyoming-state chartered bank that can accept deposits and conduct digital asset activity. The Wyoming state legislature also enacted a digital asset law, setting off a series of amendments over the years to accommodate digital assets. LINK(link is external).
7.25.19 – The SEC issues No Action Letter for Pocketful of Quarters, Inc. LINK(link is external).
7.8.19 – The SEC and FINRA publish a joint statement on the custody of digital asset securities. LINK(link is external).
5.9.19 – FinCEN issues guidance on convertible virtual currencies. LINK(link is external).
4.24.19 – The SEC and The CFTC issue a joint alert regarding fraudulent digital asset trading websites. LINK(link is external).
4.3.19 – The SEC issues No Action Letter for TurnKey Jet, Inc. LINK(link is external).
4.3.19 – The SEC FinHub publishes comprehensive guidance, or a “framework,” to evaluate whether a digital asset is considered a security under the investment contract test. LINK(link is external).

2018

11.27.18 – LabCFTC issues a primer on smart contracts. LINK(link is external).
11.16.18 – The SEC publishes a statement on digital asset securities issuances and trading. LINK(link is external).
10.18.18 – The SEC launches FinHub. LINK(link is external).
7.31.18 – The OCC begins accepting national bank charter applications from financial technology companies. LINK(link is external).
7.16.18 – The CFTC issues an advisory bulletin on digital tokens cautioning customers to conduct extensive research on digital coins and tokens. LINK(link is external).
6.14.18 – The SEC Director of Corporate Finance, William Hinman, gives the speech “Digital Asset Transactions: When Howey Met Gary (Plastic).” LINK(link is external).
5.21.18 – The CFTC issues an advisory on virtual currency derivatives. LINK(link is external).
3.23.18 – The IRS issues a bulletin reminding taxpayers to report virtual currency transactions. LINK(link is external).
3.7.18 – The SEC publishes a statement regarding potentially unlawful digital asset trading platforms. LINK(link is external).
2.15.18 – The CFTC issues an advisory, warning consumers against “pump-and-dump” schemes. LINK(link is external).
1.24.18 – The SEC and The CFTC issue a joint op-ed on distributed ledger technology (DLT). LINK(link is external).
1.18.18 – The SEC publishes a staff letter on fund innovation and cryptocurrency-related holdings. LINK(link is external).

2017

12.15.17 – The CFTC issues a proposed interpretation on the delivery of virtual currency in retail transactions. LINK(link is external). The CFTC also issues a virtual currency resource page. LINK(link is external).
12.11.17 – The SEC Chairman Jay Clayton publishes a statement on ICOs. LINK(link is external).
12.1.17 – The CFTC issues a statement on self-certified statement on contracts for Bitcoin product. LINK(link is external).
11.1.17 – The SEC publishes a statement on celebrity-backed ICOs. LINK(link is external).
10.17.17 – LabCFTC issues a primer on virtual currencies. LINK(link is external).
7.25.17 – The SEC publishes investigation of a decentralized autonomous organization, commonly known as the “DAO Report” (LINK(link is external)) and also issues an Investor Bulletin on Initial Coin Offerings (ICOs). LINK(link is external).
5.17.17 – The CFTC launches LabCFTC. LINK(link is external).
5.10.17 – The Conference of State Bank Supervisors (CSBS) Announces Vision 2020 for Fintech and Non-Bank Regulation. LINK(link is external).

2016

2015

10.5.15 – The New York Department of Financial Services (NYDFS) announces charters or licenses for three virtual currency firms – Gemini, Circle, and itBit. LINK(link is external).
9.17.15 – The CFTC defines cryptocurrencies as commodities under the Commodity Exchange Act (CEA). LINK(link is external).
6.24.15 – The New York Department of Financial Services (NYDFS) promulgates regulations that allow for a “BitLicense” for limited purpose trust charters. LINK(link is external).

2014

3.25.14 – The IRS publishes virtual currency guidance for tax purposes. LINK(link is external).
3.17.14 – The Washington state legislature enacts the Washington Trust Institutions Act, which separates trust companies from the Washington Commercial Bank Act and codifies trust company laws under Title 30B (with an effective date of 1.5.15), providing another avenue for FinTechs to charter as a trust company. LINK.
1.30.14 – FinCEN publishes determination letters related to Virtual Currency Mining Operations (LINK) and Virtual Currency Software Development. LINK(link is external).

2013

5.13 – Plaid is launched, providing technology that allows customer’s mobile phone apps to connect with the customer’s bank. LINK(link is external).
3.18.13 - FinCEN issues guidance for administering, exchanging, or using virtual currencies.  LINK.(link is external)

2011

7.21.11 - FinCEN implements a rule clarifying which entities are considered money services businesses and therefore must comply with the Bank Secrecy Act. LINK(link is external).

2009

8.09 – Venmo is launched, providing money transfers through a mobile phone application. LINK(link is external).
1.03.09 – Bitcoin blockchain launched when the first block, called the genesis block, was mined. The first test transaction took place about one week later. LINK(link is external).

2007

The housing bubble collapses due to the subprime mortgage industry, plunging the United States into a recession (The Great Recession). LINK(link is external).

2003

1998

PayPal is launched, providing online money transfers. LINK(link is external).

1993

1971

The NASDAQ is established as an exchange that uses a computerized system to trade securities. LINK(link is external).

1970

The National Credit Union Administration (NCUA) is established to charter and supervise federal credit unions. The NCUA insures dollar-for-dollar, a customers’ deposits held in a single credit union up to a certain amount. Currently, customer deposits are insured up to $250,000 per institution. LINK(link is external).

1967

The first automatic teller machine (ATM) is installed at Barclays Bank. LINK(link is external).

1950

The Diner’s Club Card becomes the world’s first credit card to be widely used and accepted. LINK(link is external).

1946

The Howey Test is established (based on former case law) in the seminal Supreme Court case, SEC v. WJ. Howey Co., 328 U.S. 293, 66 S. Ct. 1100 (1946). The Howey test, and subsequent case law, is used to determine whether a security exists in the form of an investment contract. Using the test, an investment contract exists when: there is an investment of money or other consideration, in a common enterprise, with the expectation of profits, to be derived primarily from the efforts of others. LINK(link is external).

1940

Congress passes the Investment Company Act of 1940 (’40 Act), which regulates certain companies that are engaged in investing, reinvesting, holding, or trading securities, and the securities those companies issue. LINK(link is external).

1939

Congress passes the Trust Indenture Act of 1939, which aimed to protect bond holders and provide requirements that at trustee must follow when administering a trust indenture. LINK(link is external).

1935

1934

Congress passes the Securities Exchange Act of 1934 (Exchange Act), which establishes The Securities and Exchange Commission (SEC) to help restore investor confidence after the stock market crash of 1929. LINK(link is external).

1933

Congress passes the Securities Act of 1933 (Securities Act), which requires securities issuers to make mandatory disclosures about the investment they are selling and also requires that the issuance is not based on fraudulent information or practices. LINK(link is external).
The Federal Deposit Insurance Commission (FDIC) is established to respond to the bank failures in the 1920s and 30s. The FDIC insures dollar-for-dollar, a customers’ deposits held in a single banking institution up to a certain amount. Currently, customer deposits are insured up to $250,000 per institution. LINK(link is external).

1929

The stock market crashes, plunging the United States into a decade-long recession (The Great Depression), spurring several federal regulatory reforms and programs. LINK(link is external).

1927

The Securities Department becomes the Securities Division, and is transferred to the Department of Business Licenses (precursor to the Department of Licensing and DFI).

1923

The Securities Department is established under the Washington Secretary of State (precursor to Department of Licensing and DFI), and the Washington state legislature passes the Securities Act, requiring that broker-dealers be registered with the Securities Department. LINK.

1918

The Federal Reserve creates Fedwire, which allows member banks to electronically transfer funds. LINK(link is external).

1913

The Federal Reserve System is created by the enactment of the Federal Reserve Act, establishing a central banking system for the United States. LINK(link is external).

1907

A global financial crisis hits the U.S., leading to the creation of the Federal Reserve System and spurring other regulatory reforms. LINK(link is external).

1863

The Office of the Comptroller of the Currency (OCC) is established under the National Currency Act to charter and supervise National Banking Associations, commonly known as National Banks. LINK(link is external).