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CFPB: Fixing Something That’s Not Broken – But Setting Forth a Framework for Abusive Conduct

The Consumer Financial Protection Bureau (“CFPB” or “Bureau”) recently issued a proposed rule that would prohibit financial institutions from charging nonsufficient funds (“NSF”) fees on instantaneously declined transactions....more

Proposed SEC Custody Rule Amendments Could Drive Structural Changes in the Digital Asset Industry

The U.S. Securities and Exchange Commission (“SEC”) recently proposed amendments to its so-called custody rule[1] under the Investment Advisers Act of 1940 (“Advisers Act”). The Proposed Rule seeks to expand the range of...more

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