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New York State Department of Financial Services Takes Aim at Blockchain Entities Circumventing Sanctions on Russia

Blockchain regulation continues to be the topic du jour, with increasing scrutiny from government agencies across the board. The latest comes from the New York State Department of Financial Services (DFS), which has been a...more

A Detailed Look At The CFPB’s Historic Approval of Payactiv’s Earned Wage Access (EWA) Program under Regulatory Sandbox Policy

Last week, we reported that on December 30, 2020, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issued compliance assistance sandbox (“CAS”) approval to Payactiv, Inc. (“Payactiv”) regarding specific aspects...more

States Sue to Set Aside OCC’s True Lender Rule

New York, California and six other States filed a widely expected lawsuit on January 5 seeking to invalidate the “True Lender” Rule recently issued by the Office of the Comptroller of the Currency (“OCC”). As we previously...more

CFPB’s Fee-Free Model Requirement Set Forth In Its Wage Access Advisory Opinion Raises More Questions

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

CFPB Finalizes Advisory Opinion Program Opening Door for Those Seeking Clarity on Ambiguous Statutory or Regulatory Questions

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

Fintech Company Avoids Murky Regulatory Landscape by being the First U.S. Fintech Company to Acquire a Regulated Bank

For the first time, a U.S. fintech company is acquiring a regulated U.S. bank, which will give it access to a stable and cheaper source of funding – as well as a national bank charter. On February 18th, LendingClub, one of...more

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