Timothy R. McTaggart

Timothy R. McTaggart

Pepper Hamilton LLP

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New York BitLicense Rules Have Far-Reaching Effects on Virtual Currency Businesses

The final rules’ significant operational requirements for licensees could prove to be expensive and substantial barriers to entry for small businesses interested in engaging in virtual currency business activities in New...more

6/30/2015 - Bitcoin BitLicense Final Rules Financial Institutions NYDFS SAR Virtual Currency

CFPB Using its Enforcement Powers Yet Again for UDAAP Violations, This Time Against PayPal

Even after the PayPal settlement, the definition of “abusive” remains as subjective and fact specific as ever. On May 19, PayPal agreed to a $25 million settlement with the Consumer Financial Protection Bureau (CFPB or...more

6/18/2015 - Abusive Acts CFPB Civil Penalty Fund Deceptive Intent Dodd-Frank Failure To Disclose PayPal Redress Payments Sprint Telecommunications UDAAP

CFPB to Publicly Disclose Consumer Complaint Database Narratives

On March 19, the Consumer Financial Protection Bureau (CFPB or Bureau) adopted a proposal to publicly disclose consumer complaint narratives in its Consumer Complaint Database. The Bureau also published its final policy...more

3/31/2015 - CFPB Consumer Complaint System Consumer Financial Products Popular Public Disclosure

CFPB Request for Information Targets Credit Card Debt Collection and Ability to Repay

The Consumer Financial Protection Bureau (CFPB or Bureau) announced on March 17 that it is seeking public comment, via a Request for Information, ahead of a second study on the credit card market. With this request, the...more

3/25/2015 - Banking Sector CARD Act CFPB Credit Card Agreements Credit Cards Public Comment

Observation 2.0: The Anti-Evasion Provision of the Volcker Rule

Overview This Client Alert continues Pepper’s observations on the Volcker Rule. Critical attention should be paid to the Volcker Rule’s anti-evasion provision, a powerful tool granted by Congress to the regulatory agencies to...more

1/9/2015 - Bank Examinations Bank Holding Company Banks Compliance Dodd-Frank Federal Reserve Prudential Regulation Authority Regulation Z Strategic Enforcement Plan TILA Volcker Rule

Evolving State Supervision: Issues Arising From State Qualification Standards and "SAFE" Act Licensing, and Coordination with the...

In This Presentation: - Events That Changed Our World; And Yours Too! - Current Issues in Licensing - State Coordination With CFPB - The Path to Coordination - Responsibilities of the...more

12/3/2014 - Banking Sector CFPB Dodd-Frank FSOC MLO Licenses Mortgage Loan Servicing Standards NMLS Regulatory Standards SAFE Act SAFE MLO Supervision

Compliance in 140 Characters or Less: FFIEC Supervisory Guidance on Financial Institutions’ Use of Social Media

Of critical importance for any financial institution using Twitter or other social media for business marketing and promoting purposes, the Federal Financial Institutions Examination Council (FFIEC) has issued final...more

7/15/2014 - Banking Sector Corporate Counsel FFIEC Final Guidance Marketing Risk Management Social Networks Twitter

FFIEC Increasingly Focuses on Cybersecurity Awareness

The Federal Financial Institutions Examination Council (FFIEC), under the leadership of its Chairman Thomas J. Curry, is increasingly focused on cybersecurity risks to financial institutions. At the end of June 2014, the...more

7/8/2014 - Banks Cybersecurity Data Breach Data Protection FFIEC

Top 5 Things You Should Know About Online Direct (P2P) Lending Law And Regulations — Before You Do Anything Else!

Few people following the crowdfunding space have been able to ignore the recent meteoric rise of online direct lending, often called “peer-to-peer” (P2P) lending. What started out as a simple one-to-multiple consumer lending...more

4/30/2014 - Broker-Dealer Crowdfunding FINRA Investment Adviser Investment Opportunities Lending SEC

The CFPB Issues Proposed International Money Transfer Larger Participant Rule

Proposed rule would subject international money transmitters with at least one million aggregate annual transfers to the CFPB’s supervision and examination of compliance with federal consumer financial laws....more

2/10/2014 - Banks CFPB Larger Participant Money Transfer

Observation 1.2 On The Volcker Rule: Foreign Banking Entities – Location, Location, Location

On December 10, 2013, the Board of Governors of the Federal Reserve System (FRB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), the Securities and Exchange Commission (SEC) and...more

1/17/2014 - Banks CFTC Collateralized Debt Obligations FDIC Federal Reserve Hedge Funds OCC Private Equity Proprietary Trading SEC Trust Preferred Securities Volcker Rule

The Community Reinvestment Act (CRA): New And Revised Interagency Questions And Answers Leaves Some Questions

The Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board) and the Federal Deposit Insurance Corporation (FDIC) (collectively the Agencies) adopted as final the Interagency...more

12/12/2013 - Banks Community Reinvestment Act FDIC Federal Reserve OCC

Bitcoin As A Medium Of Exchange

Bitcoin, when used as a medium of exchange, rather than as an investment vehicle, shows users many potential benefits. Part of the appeal is that bitcoins cannot be created at will and the supply of bitcoin, while large...more

8/5/2013 - Bitcoins Virtual Currency

The Rise Of Bitcoin

Bitcoin is a virtual currency without physical form or governmental authorization. It trades freely via electronic means. Although rare, bitcoin may also be transferred in person, by a laptop or tablet computer. Bitcoins come...more

7/16/2013 - Bitcoins FinCEN Global Economy Mobile Devices Virtual Currency

Virtual Currency: Recent Federal Regulatory Considerations

Bitcoin is a virtual currency – it has no physical form in paper or metal and is not connected with any central bank or governmental authority. It is freely tradable via the internet or other electronic means. Transactions in...more

5/2/2013 - Bitcoins FinCEN Money Services Business Virtual Currency

The OCC’s New Stance: FDIC Insurance Required For ‘Trust-Only’ National Banks

Traditionally, the Office of the Comptroller of the Currency (OCC) did not require a national bank seeking to engage in non-depository, trust-only activities (a “trust-only bank”) to obtain Federal Deposit Insurance...more

4/23/2013 - Dodd-Frank FDIC OCC Trust-Only Banks

Will New U.S. Court Of Appeals Decision On ‘Recess Appointments’ Stay Dodd-Frank Powers Granted To CFPB And Vacate Certain...

Holding that recess appointments authorized by the Recess Appointments Clause of the U.S. Constitution are limited to “intersession recesses” – “the period between sessions of the Senate when the Senate is by definition not...more

3/5/2013 - Barack Obama Canning v NLRB CFPB De Facto Officer Doctrine Dodd-Frank Pro Forma Sessions Recess Appointments Richard Cordray

The Impact Of The CFPB’s Appraisal Rule

On January 18, 2013, the Consumer Financial Protection Bureau (CFPB) issued a final rule (the Appraisal Rule) implementing an amendment to the Equal Credit Opportunity Act (ECOA) that revises Regulation B’s provisions...more

2/28/2013 - Appraisal CFPB Credit Unions Dodd-Frank ECOA Final Rules Higher-Priced Mortgage Loans Mortgages NCUA Regulation B

FSOC Recommends and Seeks Comment on Money Market Mutual Fund Reform

On November 13, the Financial Stability Oversight Council (FSOC) voted unanimously to advance its report entitled “Proposed Recommendations Regarding Money Market Mutual Fund Reform.” FSOC was established by the Dodd-Frank...more

11/19/2012

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