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
The Consumer Financial Protection Bureau (CFPB) has remained busy as we head into the final week of 2021. The agency released updated FAQs regarding the Electronic Fund Transfer Act (EFTA) and Regulation E, issued orders to...more
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
The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued Sanctions Compliance Guidance for the Virtual Currency Industry. The guidance published on October 15, 2021, outlines OFAC’s...more
Innovative companies and platforms that seek to bring new virtual currency products and services to market in the US generally need to consider the potential applicability of US state money transmission licensing laws. How...more
The California Department of Financial Protection and Innovation (DFPI) has finally adopted final rules relating to the scope of the agent-of-a-payee exemption under the California Money Transmission Act (MTA), Cal. Fin. Code...more
Any company that intermediates payments for other parties ─ such as a marketplace platform, a billing service, a payment facilitator or a B2B platform provider ─ must take into consideration the applicability of money...more
The US Consumer Financial Protection Bureau continues to focus on fair lending and is poised to increase enforcement actions. On March 9, the CFPB issued an interpretive rule to clarify that the prohibition against sex...more