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CFPB Finalizes Long-Awaited Rule to Accelerate Open Banking Development; Immediately Sued

On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) finalized a rulemaking on Personal Financial Data Rights (the “Final Rule”). The Final Rule is intended to accelerate a shift towards open banking in the...more

Recent Developments in the Payment Industry

Join us for a new episode of Financial Services Focus with Mayer Brown Partner, David Beam, and Houlihan Lokey Managing Director, Kartik Sudeep. Beam and Sudeep discuss developments in the payments industry, including...more

FDIC Proposes New Recordkeeping Requirements for Custodial Accounts

On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed extensive new recordkeeping requirements and other compliance obligations (the “Proposal” ) for certain types of deposit accounts frequently...more

Federal Reserve Wins Two Master Account Lawsuits

At the end of March, components of the US Federal Reserve System (“FRS” or the “Fed”) prevailed in two lawsuits brought by depository institutions seeking master accounts.1 These decisions have significant implications for...more

How Many Digits? FinCEN Seeks Comment on Bank Customer Identification Requirements

On March 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), in consultation with the staffs of the federal banking agencies, issued a request for information and comment (the “RFI”)...more

Virtual Currency Activity Prior Approval Requirement Established by NYDFS

On December 15, 2022, the New York Department of Financial Services (“NYDFS”) issued guidance clarifying that all New York banking organizations are required to obtain prior agency approval for virtual currency-related...more

Making Sense of Banking as a Service (BaaS): Recent Applications and Considerations

Banking as a Service (“BaaS”) refers to arrangements where licensed banks integrate their digital banking services directly into the products of other non-bank businesses. Join Mayer Brown partners David Beam, Rohith George...more

Illinois Imposes Strict 36% Usury Cap for a Range of Consumer Finance Products and Providers

On March 23, 2021, Illinois Governor JB Pritzker signed into law Senate Bill 1792, enacting the Predatory Loan Prevention Act (PLPA) and capping interest at an “all-in” 36% APR (similar to the Military Lending Act’s MAPR) for...more

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