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CFPB Doubles Down on Buy Now, Pay Later Interpretive Rule in New FAQs

On September 18, 2024, the Consumer Financial Protection Bureau (CFPB) published a compliance aid to its May 2024 interpretive rule, which classifies certain providers of buy now, pay later (BNPL) products as card issuers...more

FDIC’s Proposed Brokered Deposit Rule Could Adversely Impact Fintech-Bank Partnerships

In late July 2024, the Federal Deposit Insurance Corporation (FDIC) board of directors proposed a rule that would revise its standards on banks accepting brokered deposits. The proposed rule would expand the definition of...more

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

SEC, FinCEN Propose to Mandate Customer Identification Programs for Registered Investment Advisers, Exempt Reporting Advisers

On May 13, 2024, the US Securities and Exchange Commission (SEC) and the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) jointly issued a notice of proposed rulemaking that would require investment...more

CFPB Hints at Future Regulatory Action Targeting Credit Card Rewards Programs

On May 9, 2024, the Consumer Financial Protection Bureau (CFPB) published a report highlighting common themes in complaints received from consumers, including mismatches between marketing and actual terms, devaluations of...more

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