Sean Ruff

Sean Ruff

Morrison & Foerster LLP

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CFPB Takes Action Against Lead Aggregators

On December 17, 2015, the Consumer Financial Protection Bureau (“CFPB”) announced that it has taken action against lead aggregators that resold sensitive personal information to lenders and debt collectors. In a complaint...more

12/23/2015 - CFPB Debt Collectors Enforcement Actions Lead Generators Lenders Personal Data UDAAP

Loan to San Bernardino Attacker Generates New Focus on Online Marketplace Lending and Terrorism Financing

News that an online marketplace lender extended a $28,500 loan to Syed Rizwan Farook, one of the alleged San Bernardino attackers, just two weeks before the attack, has spurred House Financial Services Committee Chairman Jeb...more

12/14/2015 - Anti-Money Laundering Bank Secrecy Act Online Marketplace Lending Patriot Act Suspicious Activity Reports Terrorist Acts Terrorist Financing Regulations

The CSBS Finalizes Model Framework for Virtual Currencies

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

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