In an earlier article, we provided an overview of the Consumer Financial Protection Bureau’s (“CFPB”) earned wage access (“EWA”) advisory opinion. In the opinion, the CFPB identified seven requirements that for a “Covered...more
The Consumer Financial Protection Bureau (“CFPB”) announced in March 2020 that it would develop a new advisory opinion program under which it would publish in the Federal Register responses to questions seeking clarification...more
For those who haven’t previously been following, this is our third installment on COVID-19 class actions. The first installment was prospective and authored prior to any filed class actions. The second installment examined...more
On March 18, 2020, Square Inc., became the first U.S. fintech company to receive conditional approval of an Industrial Loan Company (“ILC”) charter from the Federal Deposit Insurance Corporation (“FDIC”), to pair with its...more