EDITOR’S NOTE -
The holidays came early for the financial services industry. First, the Senate voted to repeal the CFPB’s rule banning class waivers in arbitration agreements in consumer financial contracts. Then,...more
12/12/2017
/ Arbitration ,
Biometric Information Privacy Act ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Debt ,
ECOA ,
FDIC ,
FinCEN ,
HMDA ,
NYDFS ,
OCC ,
Payday Loans ,
TCPA ,
Trump Administration ,
U.S. Treasury ,
Virtual Currency
BELTWAY -
Every Last Penny Counts -
Five federal banking agencies issued a Supervisory Bulletin titled “Interagency Guidance Regarding Deposit Reconciliation Practices” (the “Guidance”). The Guidance outlines...more
6/8/2016
/ Arbitration ,
Article III ,
CID ,
Civil Investigation Demand ,
Class Action Arbitration Waivers ,
Comptroller ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Credit ,
Customer Due Diligence (CDD) ,
Data Privacy ,
Data Security ,
Debt Collection ,
ECOA ,
FDCPA ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
FFIEC ,
FHFA ,
Financial Institutions ,
FinCEN ,
FinTech ,
Hawkins v Community Bank of Raymore ,
Mobile Banking ,
Net Stable Funding Ratio (NSFR) ,
Online Marketplace Lending ,
Payday Loans ,
Payment Protection Insurance ,
PCI-DSS Standard ,
Preemption ,
RESPA ,
SCOTUS ,
Spokeo v Robins ,
Standing ,
Student Loans ,
TCPA ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Truth in Lending Act (TILA) ,
UDAAP ,
Virtual Currency ,
Volcker Rule
BELTWAY -
Finally Faster than Amazon Prime -
The Federal Reserve Board recently announced that banks and other financial institutions that use its payments system will have to be able to process same-day...more
12/8/2015
/ Arbitration ,
Automotive Loans ,
Consumer Financial Protection Bureau (CFPB) ,
Crowdfunding ,
Cybersecurity ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
HMDA ,
Preemption ,
Redlining ,
Securities and Exchange Commission (SEC) ,
Student Loans ,
TCPA ,
UDAAP ,
Virtual Currency
On September 15, 2015, the Conference of State Bank Supervisors (“CSBS”) issued its final Model Regulatory Framework on virtual currency activities (“Final Framework”). The Final Framework follows the CSBS’s December 2014...more
9/29/2015
/ Anti-Money Laundering ,
Audits ,
Bank Secrecy Act ,
CSBS ,
Cybersecurity ,
FinCEN ,
Investment ,
Licenses ,
NYDFS ,
Policy Statement ,
Recordkeeping Requirements ,
Regulatory Agenda ,
Regulatory Oversight ,
Reporting Requirements ,
Security Audits ,
Third-Party ,
Virtual Currency
On June 3, 2015, the New York Department of Financial Services (“NYDFS”) issued a final rule regarding its “BitLicense” regulatory regime (“Final Rule”). The Final Rule follows an initial proposal from July 2014 and a revised...more
There have been two recent virtual currency-related actions worthy of note: (1) the Financial Crimes Enforcement Network (“FinCEN”) announced its first civil enforcement action against a virtual currency exchanger, and (2)...more
On February 4, 2015, the New York Department of Financial Services (“NYDFS”) issued for public comment a revised proposed rule to implement a “BitLicense” regulatory regime (the “2015 Proposal”). As discussed below, the 2015...more
On October 27, 2014, the Financial Crimes Enforcement Network (“FinCEN”) issued two administrative rulings regarding virtual currency. The first administrative ruling concerns a proposed virtual currency trading and booking...more
Yesterday, the New York Department of Financial Services (“NYDFS”) issued a proposed rule for public comment setting forth a novel and comprehensive “BitLicense” regulatory scheme for entities engaged in “Virtual Currency...more
On June 26, 2014, the U.S. Government Accountability Office (“GAO”) released a report, entitled “Virtual Currencies: Emerging Regulatory, Law Enforcement, and Consumer Protection Challenges.” The report, delivered earlier to...more
7/8/2014
/ Consumer Financial Protection Bureau (CFPB) ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
GAO ,
Information Reports ,
IRS ,
Law Enforcement ,
Legislative Committees ,
Popular ,
Property Tax ,
Virtual Currency
On January 30, 2014, the Financial Crimes Enforcement Network (“FinCEN”) issued two administrative rulings that address the application of Bank Secrecy Act (“BSA”) regulations to convertible virtual currency-related...more
On May 30, 2013, the California Department of Financial Institutions (“CADFI”) issued a cease and desist letter to Bitcoin Foundation, a not-for-profit organization established to standardize, protect, and promote the use and...more