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Are You a “Payment Processor”? Washington State Appears to Significantly Expand Scope of Its Money Transmission Act

One of the defining aspects of the payments revolution of the past few years—at least from a regulatory perspective—has been the question of whether any particular payments service is subject to regulation as money...more

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

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

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