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Not Just Fun and Games? CFPB Seeks Comments on Proposed Interpretive Rule to Place New Forms of Digital Payments, Including...

On January 15, 2025, days before the start of the Trump administration, the Consumer Financial Protection Bureau (CFPB) published a proposed interpretive rule (Proposed Rule) seeking public comment on how the Electronic Fund...more

Analyze This: The NYDFS Sets Clear Crypto Transaction Monitoring Expectations

The past year has seen a flurry of crypto-related activities by the federal financial regulators, including the issuance of reports, guidance, joint statements, and interpretive letters....more

New Strides in Crypto-Asset Regulation

On November 23, 2021, the Office of the Comptroller of the Currency (OCC) released Interpretive Letter 1179 (the “Letter”), which is the culmination of a review of prior Interpretive Letters on cryptocurrency and related...more

President’s Working Group Releases Report on Stablecoins

On November 1, 2021, the President’s Working Group on Financial Markets (PWG), along with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) (together, the “Agencies”),...more

Financial Services Report – Winter 2017

EDITOR’S NOTE - The holidays came early for the financial services industry. First, the Senate voted to repeal the CFPB’s rule banning class waivers in arbitration agreements in consumer financial contracts. Then,...more

Financial Services Report, Winter 2015

BELTWAY - Finally Faster than Amazon Prime - The Federal Reserve Board recently announced that banks and other financial institutions that use its payments system will have to be able to process same-day...more

The CSBS Finalizes Model Framework for Virtual Currencies

On September 15, 2015, the Conference of State Bank Supervisors (“CSBS”) issued its final Model Regulatory Framework on virtual currency activities (“Final Framework”). The Final Framework follows the CSBS’s December 2014...more

The NYDFS Finalizes its BitLicense Proposal

On June 3, 2015, the New York Department of Financial Services (“NYDFS”) issued a final rule regarding its “BitLicense” regulatory regime (“Final Rule”). The Final Rule follows an initial proposal from July 2014 and a revised...more

“Firsts” for the World of Virtual Currencies

There have been two recent virtual currency-related actions worthy of note: (1) the Financial Crimes Enforcement Network (“FinCEN”) announced its first civil enforcement action against a virtual currency exchanger, and (2)...more

State Virtual Currency Regulatory Developments

On February 4, 2015, the New York Department of Financial Services (“NYDFS”) issued for public comment a revised proposed rule to implement a “BitLicense” regulatory regime (the “2015 Proposal”). As discussed below, the 2015...more

FinCEN Rulings Designate Certain Virtual Currency Businesses as Money Transmitters

On October 27, 2014, the Financial Crimes Enforcement Network (“FinCEN”) issued two administrative rulings regarding virtual currency. The first administrative ruling concerns a proposed virtual currency trading and booking...more

New York DFS Proposes Sweeping Virtual Currency Licensing Scheme

Yesterday, the New York Department of Financial Services (“NYDFS”) issued a proposed rule for public comment setting forth a novel and comprehensive “BitLicense” regulatory scheme for entities engaged in “Virtual Currency...more

CFPB to Assume a Larger Role in Virtual Currency Initiatives

On June 26, 2014, the U.S. Government Accountability Office (“GAO”) released a report, entitled “Virtual Currencies: Emerging Regulatory, Law Enforcement, and Consumer Protection Challenges.” The report, delivered earlier to...more

FinCEN Issues Additional Clarifications Regarding Bitcoin and other Convertible Virtual Currency Activities

On January 30, 2014, the Financial Crimes Enforcement Network (“FinCEN”) issued two administrative rulings that address the application of Bank Secrecy Act (“BSA”) regulations to convertible virtual currency-related...more

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