Regardless of whether its recommendations are achievable in whole or in part or merely aspirational, the US Department of Treasury’s (“Treasury”) report issued on July 30, 2018—A Financial System That Creates Economic Opportunities: Nonbank Financials, Fintech and Innovation—is an ambitious, well-thought-out, comprehensive compendium of proposals to foster innovation in our financial system. Treasury deserves kudos for organizing and analyzing a disparate set of potential reforms to help synchronize old laws with new ways to conduct business. The question is whether this laudable blue-print for reform can serve as the impetus for real change given our current state of affairs. This Legal Update provides a high-level summary of the Treasury recommendations, along with a brief analysis of the key areas and some thoughts regarding the prospects for successful implementation of the pertinent proposals.
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