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The Federal Reserve’s Novel Activities Supervision Program: What Banks and Nonbanks Need to Know

Financial technology firms and certain banks and bank holding companies can expect to face increased scrutiny as the Board of Governors of the Federal Reserve System takes another step to stem risks related to crypto-assets,...more

Federal Reserve Issues Final Guidelines for Master Account Access

The Board of Governors of the Federal Reserve System (the Board), on August 15, 2022, issued final guidelines for regional Federal Reserve Banks to use when considering applications for Federal Reserve “master...more

Fintech Legal Report - July 2022

The CFPB terminates a no-action letter with an AI credit underwriter. A CFPB circular confirms that AI underwriting models are subject to anti-discrimination laws including adverse action notices....more

Fintech Legal Report - May 2022

CFPB Director Chopra Plans to Review CARD Act Rules - The day after a tough hearing with the Senate Banking Committee, on April 27, 2022, the House Financial Services Committee held a hearing in which Consumer Financial...more

Fintech Legal Report - February 2022 #2

CA DFPI Issues Interpretive Opinion on Earned Wage Access - On February 11, 2022, the California Department of Financial Protection and Innovation (DFPI) issued an interpretive opinion letter that FlexWage, a New...more

Fintech Legal Report - February 2022

CFPB Requests Info on Consumer Financial Products or Service Fees - On January 26, 2022, the Consumer Financial Protection Bureau (CFPB) announced the launch of an initiative to collect information from consumers,...more

Fintech Legal Report - November 2021

Bank Regulator Outlines Vision for Bank-Like Supervisory Regime for Crypto and Fintech Firms - On November 3, 2021, Acting Comptroller of the Currency Michael J. Hsu discussed clarifying and modernizing the bank...more

Fintech Legal Report - October 2021 #2

CFPB Initiates Inquiry into Big Tech Payment Platforms - On October 21, 2021, the Consumer Financial Protection Bureau (CFPB) ordered six large technology companies—Google, Apple, Facebook, Amazon, Square, and PayPal—to...more

Fintech Legal Report - September 2021

Federal Banking Agencies Issue Guide for Community Banks on Conducting Due Diligence on Fintech Companies - On August 27, 2021, the federal banking agencies (Federal Reserve, FDIC, and OCC) published “Conducting Due...more

Fintech Legal Report - August 2021

Senators Inquire about CFPB’s Fintech Agenda - On July 27, 2021, Senator Sherrod Brown, the Chairman of the U.S. Senate Committee on Banking, Housing, and Urban Affairs, sent a letter to the Consumer Financial Protection...more

Fintech Legal Report - July 2021

President Biden Issues an Executive Order on Competition with Implications for Financial Institutions - On July 9, 2021, President Biden issued an Executive Order on Promoting Competition in the American Economy. The...more

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