Happy post-election, post-socially-distanced Thanksgiving, and pre-New Year’s newsletter. Banks, non-banks, and FinTechs can look forward to eight days of announcements from the Biden transition team with their latkes and...more
12/11/2020
/ Arbitration ,
Banking Sector ,
Bitcoin ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Data Breach ,
Debt Collection ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
Federal Savings Associations ,
Financial Services Industry ,
FinCEN ,
FinTech ,
FRB ,
Main Street Lending Programs ,
Mobile Payments ,
OCC ,
Private Attorneys General Act (PAGA) ,
SBA ,
TCPA ,
Third-Party Service Provider
Punxsutawney Phil didn’t see his shadow, so we’re expecting an early spring. Maybe that’s why mini-CFPBs are sprouting or expanding on both coasts. Governor Cuomo announced several key measures impacting financial services...more
It seems like a natural progression for a company that provides any sort of payments-related information processing to migrate from handling data about payments to seeking to handle the payments themselves. But it can be a...more
On May 28, 2019, a Nevada resident, Morgan Rockcoons, was sentenced in the U.S. District Court for the Southern District of California to 21 months in prison for wire fraud and unlicensed money transmission. In connection...more
Last year, we noted that the Banking Department of the Vermont Department of Financial Regulation had taken the position that its money transmission law “does not exempt a payment processor or an agent of a payee from [money...more
With one eye on the New York Department of Financial Services (“NYDFS”) cybersecurity rules and the other on two of its own Commissioners who dissented, the Federal Trade Commission (“FTC”) has proposed a sweeping overhaul to...more
The payments and money transmission regulatory landscape continues to evolve. A key new development is that Michigan has affirmed by legislation that “agent of a payee” transactions meeting certain criteria are not subject...more
As we have noted on multiple occasions, one of the most important questions in the non-bank payments revolution — at least from a regulatory perspective — is whether a particular payments service is subject to regulation as...more
The Banking Department of the Vermont Department of Financial Regulation (the “Banking Department”) recently entered into a consent order with a money transmission licensing applicant (the “Applicant”). The consent order...more
BELTWAY -
The Wayback Machine -
Congress passed, and on May 24, 2018, the president signed into law, the Economic Growth, Regulatory Relief, and Consumer Protection Act (S.2155). The law makes significant changes to...more
6/8/2018
/ Arbitration ,
Auto Lease ,
Banking Sector ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Economic Growth Regulatory Relief and Consumer Protection Act ,
Fair Lending ,
FDCPA ,
FFIEC ,
FinTech ,
GAO ,
General Data Protection Regulation (GDPR) ,
HMDA ,
Securities and Exchange Commission (SEC) ,
SIFMA ,
TCPA
As we have noted previously, 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 a particular payments service is subject to...more