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US States Adopt Model Money Transmission Act, but Harmonization Remains Elusive

So far in 2024, nine states1 – Maryland, South Dakota, Wisconsin, Kansas, Maine, Vermont, South Carolina, Missouri and Connecticut – have passed legislation or enacted regulations based, to varying degrees, on the Model Money...more

CFPB Highlights Financial, Privacy Risks of Consumer Transactions on Gaming Platforms

On April 4, 2024, the Consumer Financial Protection Bureau (CFPB) issued a report examining the growth and privacy risks of financial transactions in online video games and virtual worlds, noting that Americans spent...more

CFPB Signals Desire to Expand Supervision of Nonbank Payments Firms

During remarks at a payments-focused event on October 6, 2023, Consumer Financial Protection Bureau (CFPB) Director Rohit Chopra signaled that the bureau intends to expand its oversight of digital payments and the companies...more

Recent Developments: Silicon Valley Bank and Signature Bank

After depositors rushed to withdraw funds from Silicon Valley Bank (SVB), on Friday, March 10, 2023, the US bank was closed by the California Department of Financial Protection and Innovation (DFPI), and the Federal Deposit...more

Common Questions Regarding Access to Funds After Failure of an FDIC-Insured Bank

Background On Friday, March 10, 2023, Silicon Valley Bank (SVB) was closed by the California Department of Financial Protection and Innovation (DFPI). The Federal Deposit Insurance Corporation (FDIC) was named Receiver and...more

Arizona Embraces CSBS Model Money Transmission Law; West Virginia Incorporates Some Key Provisions

On May 20, 2022, Arizona Gov. Doug Ducey signed Senate Bill 1580, which effectively replaces Arizona’s current money transmission law with the Model Money Transmission Modernization Act (the Model Act) announced by the...more

Federal Reserve Seeks Comments on a US Central Bank Digital Currency

The Federal Reserve Board recently released a discussion paper and is seeking public comments on the potential benefits and risks, and related policy considerations, of introducing a central bank digital currency (CBDC) in...more

36-Hour Breach Notification Rule to Go into Effect for Banking Organizations

On November 18, 2021, three US agencies – the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (FRB) and the Federal Deposit Insurance Corporation (FDIC) – issued a joint rule concerning...more

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