In 2023, the digital asset industry demonstrated remarkable resilience amidst significant challenges, including the dissolution of several digital asset financial services companies, numerous bank failures, and a $4.7 billion...more
4/23/2024
/ Banks ,
Blockchain ,
Consumer Financial Products ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
Distributed Ledger Technology (DLT) ,
FDIC ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
OCC ,
Policy Statement ,
Smart Contracts ,
U.S. Treasury
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more
4/17/2024
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Digital Assets ,
FDCPA ,
FDIC ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
IRS ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC)
In this special crossover episode with Payments Pros and The Crypto Exchange, Ethan Ostroff, James Kim, and Carlin McCrory discuss the Consumer Financial Protection Bureau's (CFPB) proposed rule to supervise large tech...more
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more
2/27/2024
/ Bank Secrecy Act ,
Banks ,
Bitcoin ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Digital Assets ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Non-Fungible Tokens (NFTs) ,
Overdraft Fees ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
State Attorneys General
In this episode of The Crypto Exchange, Troutman Pepper Partner Ethan Ostroff welcomes his colleague Addison Morgan to discuss California's Digital Financial Assets Law (DFAL), set to take effect on July 1, 2025. The DFAL...more
We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures, consumer financial services providers faced a challenging...more
2/1/2024
/ Automotive Loans ,
Banks ,
Class Action ,
Consumer Bankruptcy ,
Consumer Financial Products ,
Debt Collection ,
Digital Assets ,
Fair Lending ,
Financial Services Industry ,
FinTech ,
Mortgages ,
Student Loans ,
Tribal Loans ,
Uniform Commercial Code (UCC)
In November 2022, the Financial Industry Regulatory Authority (FINRA) launched a targeted crypto asset sweep, reviewing more than 500 retail communications related to crypto assets from member firms....more
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more
1/24/2024
/ Bank Secrecy Act ,
Buy Now Pay Later (BNPL) ,
Cease and Desist Orders ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Justice (DOJ) ,
Digital Assets ,
FDIC ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Misleading Statements ,
Regulatory Agenda ,
U.S. Treasury
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more
1/18/2024
/ Broker-Dealer ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Consumer Reporting Agencies ,
Cryptoassets ,
Digital Assets ,
Do Not Call List ,
Due Diligence ,
Federal Trade Commission (FTC) ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FTC Act ,
OCC ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC)
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more
12/13/2023
/ Banks ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Crypto Exchanges ,
Cryptocurrency ,
Digital Assets ,
Federal Reserve ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Investors ,
Notice of Proposed Rulemaking (NOPR) ,
Public Comment ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Stablecoins
On November 20, 2023, the California Department of Financial Protection and Innovation (DFPI) issued an invitation for comments on proposed application-related rulemaking under the Digital Financial Assets Law (DFAL). This...more
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more
11/21/2023
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Consumer Reporting Agencies ,
Cryptoassets ,
Cryptocurrency ,
Debt Collection ,
Department of Financial Services ,
Digital Assets ,
Fair Credit Reporting Act (FCRA) ,
FDCPA ,
Federal Housing Administration (FHA) ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Regulation V
On October 13, California Governor Gavin Newsom (D) signed Assembly Bill 39 (Digital Financial Assets Law). This new law broadly empowers the California Department of Financial Protection and Innovation (DFPI) to govern...more
11/7/2023
/ AML/CFT ,
Anti-Money Laundering ,
ATMs ,
Bank Secrecy Act ,
California ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptoassets ,
Cryptocurrency ,
Department of Financial Protection and Innovation (DFPI) ,
Digital Assets ,
Disclosure Requirements ,
FDIC ,
Financial Regulatory Reform ,
Financial Services Industry ,
Money Laundering ,
New Regulations ,
Securities and Exchange Commission (SEC) ,
Stablecoins
As reported in more detail on our Regulatory Oversight blog, the Securities and Exchange Commission’s Division of Examinations recently released its 2024 Examination Priorities report. The report underscores the SEC’s intent...more
10/31/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Broker-Dealer ,
BSA/AML ,
Cryptocurrency ,
Customer Identification Program (CIP) ,
Digital Assets ,
Emerging Technologies ,
Financial Institutions ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
On October 19, the Securities and Exchange Commission (SEC) dismissed its claims against Ripple Labs, Inc. (Ripple) executives Bradley Garlinghouse and Christian Larsen for allegedly aiding and abetting Ripple’s violations of...more
10/23/2023
/ Cryptoassets ,
Cryptocurrency ,
Cybersecurity ,
Digital Assets ,
Enforcement Actions ,
Interlocutory Appeals ,
Popular ,
Ripple ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Summary Judgment ,
Trading Platforms
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Finance Services industry over the past week...more
10/4/2023
/ Asset Management ,
Blockchain ,
CFTC ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Digital Assets ,
EFTs ,
Enforcement Actions ,
Ethereum ,
Fair Credit Reporting Act (FCRA) ,
Federal Trade Commission (FTC) ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
Money Market Funds ,
OCC ,
Rare Earth Metals ,
Regulatory Agenda ,
Student Loans ,
UBS
In the ever-evolving world of digital assets and law, Grayscale Investments, LLC (Grayscale) found itself at the pinnacle of a major decision by the Court of Appeals for the District of Columbia. On August 29, the court...more
9/8/2023
/ Administrative Procedure Act ,
Arbitrary and Capricious ,
Bitcoin ,
Consumer Financial Products ,
Digital Assets ,
ETFs ,
Exchange-Traded Products ,
FinTech ,
Futures ,
Popular ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
In this episode of The Crypto Exchange, Troutman Pepper Partner Ethan Ostroff welcomes his colleagues Mike Lowe and Matt Orso to discuss the U.S. Department of Treasury's Illicit Finance Risk Assessment of Decentralized...more
To help you keep abreast of relevant activities, below find a breakdown of some of the biggest events at the federal and state levels to impact the Consumer Finance Services industry this past week...more
9/6/2023
/ Bitcoin ,
Blockchain ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Dodd-Frank ,
FDIC ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Putative Class Actions ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
In this episode of The Crypto Exchange, our host Ethan Ostroff joins his colleagues Chris Willis and Trey Smith to discuss the current landscape of cryptocurrency regulation and enforcement. Our team offers insights to the...more
On August 11, in the case of Yuille v. Uphold HQ Inc., the Southern District of New York was tasked with determining whether the Electronic Funds Transfer Act (EFTA) applies to digital asset-based accounts. The court...more
In this episode of The Consumer Finance Podcast, Troutman Pepper Partner Chris Willis is joined by colleagues Ethan Ostroff and Trey Smith to discuss the current landscape of cryptocurrency regulation and enforcement. Our...more
In this episode of The Crypto Exchange, Troutman Pepper Partner Ethan Ostroff welcomes his colleagues Kim Phan and Addison Morgan to discuss the recent enforcement actions brought by the Federal Trade Commission (FTC) against...more
8/18/2023
/ CFTC ,
Cryptoassets ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
FTC Act ,
Gramm-Leach-Blilely Act ,
Securities and Exchange Commission (SEC) ,
Securities Fraud
On August 8, the Federal Reserve Board (Fed) issued a press release providing additional information on its Novel Activities Supervision Program (Program) to monitor novel activities in the banks it oversees. Novel activities...more
8/17/2023
/ Application Programming Interface (APIs) ,
Banks ,
Blockchain ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
Distributed Ledger Technology (DLT) ,
Financial Institutions ,
Financial Services Industry ,
Securities and Exchange Commission (SEC) ,
Virtual Currency
Deceptive advertisements, market manipulation, misappropriation of customer funds, and “Ask Me Anything (AMA)” sessions served as the catalysts of a civil enforcement action the Federal Trade Commission (FTC) recently filed...more
7/18/2023
/ Civil Monetary Penalty ,
Consumer Protection Act ,
Cryptocurrency ,
Digital Assets ,
Dodd-Frank ,
Enforcement Actions ,
FDCPA ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
FTC Act ,
Gramm-Leach-Blilely Act ,
Regulatory Agencies ,
Unfair or Deceptive Trade Practices