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Wisconsin Signs Earned Wage Access Bill into Law

On March 21, Wisconsin enacted into law Assembly Bill 574, positioning it as the third state, following Nevada and Missouri, to establish a comprehensive regulatory framework for earned wages access (EWA) services and...more

Bank Partnership Moves to Dismiss Class Action Asserting Violations of Georgia Rate Cap Law

On January 29, a Missouri-based bank and its Kansas-based fintech loan servicer filed a joint motion to dismiss a purported class action filed against them alleging violations of the Georgia Installment Loan Act (GILA) and...more

Eye on Privacy: 2023 Year in Review

ARTIFICIAL INTELLIGENCE - What is the Privacy Impact of the White House AI Order for Businesses? Posted November 28, 2023 Biden’s sweeping AI Executive Order sought to have artificial intelligence used in accordance...more

Washington D.C. Introduced Rate Exportation Opt-Out and “Anti-Evasion” Bill

On November 30, Washington D.C. introduced District of Columbia Council Bill B 25-0609, which would opt the state out of Section 521 of the Depository Institutions Deregulation and Monetary Control Act of 1980 (“DIDMCA”) with...more

Michigan Supreme Court Limits Applicability of Usury Savings Clauses

On June 23, in Soaring Pine v. Park St Grp, the Michigan Supreme Court held that under certain circumstances, a lender cannot avoid liability for charging illegally high interest rates by including a usury savings clause in...more

Texas, Louisiana Enact Digital Asset Licensing Legislation

In recent weeks, Texas and Louisiana became the latest states to enact legislation establishing licensure requirements for digital asset service providers. In June, Texas enacted HB 1666, which adds practice restrictions...more

Pennsylvania AG Targets Rent-to-Own Company for Alleged Deceptive and Predatory Practices

On May 15, the Pennsylvania Attorney General Attorney General Michelle Henry announced a $11 million settlement with a rent-to-own lender and its subsidiaries accused of engaging in predatory financing practices. Among other...more

Georgia Introduces New Commercial Financing Disclosure Requirements

On May 1, Georgia signed SB 90 to become the latest state to require disclosures for small-business financing... Providers of commercial financing in the amount of $500,000 or less who conduct more than five transactions in...more

Colorado Approves DIDMCA Opt-Out, Raising Concerns for Consumer Credit Access

Earlier this month, the Colorado legislature voted to approve HB23-1229, which would opt the State out of Section 521 of the Depository Institutions Deregulation and Monetary Control Act of 1980 (“DIDMCA”), a federal law...more

Massachusetts AG Settles Enforcement Action Against Auto Lender

On February 2, the Massachusetts Attorney General announced that her office entered into an assurance of discontinuance with an auto loan provider to settle allegations of certain illegal auto loan collection practices....more

FinTech Prevails in Texas “True Lender” Challenge

On January 11, 2023, a Texas federal court dismissed a class action lawsuit against a leading financial technology company alleging it violated Texas usury laws by charging interest on loans it made through a partnership with...more

AZ Attorney General Concludes Non-Recourse EWA Not a Loan

On December 18, the Arizona Attorney General issued an opinion on earned wage access (EWA), which determined that fully non-recourse EWA products do not constitute consumer loans subject to consumer loan regulations, and...more

CFPB and State Regulators Hone in on Interest-Bearing Crypto Accounts

On November 22, the CFPB denied a crypto lending institution’s petition for an order modifying a pending civil investigative demand (“CID”) that the Bureau issued to the institution in December of 2021. The CFPB issued the...more

New York Publishes Proposed Rules on Commercial Financing Disclosures

On September 14, the New York Department of Financial Services (NYDFS) published a notice of proposed rules under New York’s Commercial Financing Disclosure Law (CFDL)...more

House Passed SECURE Notarization Act of 2022

Recently, the House of Representatives passed the SECURE Notarization Act of 2022 (H.R. 3962). The legislation that creates federal minimum standards to allow notaries in all states to perform remote online notarization...more

California Approves Commercial Financing Disclosure Regulations

On June 9, the California Office of Administrative Law (OAL) approved the Department of Financial Protection and Innovation’s (DFPI) proposed commercial financing disclosure regulations issued pursuant to SB 1235...more

California Regulator Seeks Comment on Future Crypto Guidance

On June 1, the California DFPI began formally seeking input from the public to assist in developing guidance and regulatory clarity for Blockchain and Crypto companies as directed by Governor Newsom’s Executive Order (which...more

Connecticut Stops FinTech from Unlicensed Lending Activities

On May 4, the Connecticut Department of Banking issued a temporary cease and desist order directing a peer-to-peer lending platform that connected borrowers with third-party lenders to cease its lending-related activities on...more

Utah Enacts Commercial Financing Disclosure Requirement

On March 24, Utah Governor Spencer Cox signed SB 183 into law making Utah the third state in the country to enact a Truth in Lending-like commercial financing disclosure law.  Utah joins California and New York to adopt such...more

Fintech Flips Script, Sues California Regulator Over 36% Rate Cap Law

On March 7, a Chicago-based FinTech company  filed a Complaint for Declaratory and Injunctive Relief in Los Angeles County Superior Court against the Commissioner of the California Department of Financial Protection and...more

Virginia Approves Bill Allowing Banks to Offer Cryptocurrency Custody Services

On March 3, Virginia passed a new bill (HB 263) permitting banks in the Commonwealth to provide its customers with crypto custody services “so long as the bank has adequate protocols in place to effectively manage risks and...more

DFPI Approves EWA Provider

On February 11, the California DFPI issued an opinion letter in response to an EWA provider’s request for a specific ruling from the DFPI about whether the company’s EWA solution is subject to licensure under the California...more

California and Georgia Reach Settlement with Rent-to-Own Companies

In two unrelated settlements, the California DFPI and Georgia attorney general each recently settled with rent-to-own companies. In the California settlement that was announced on January 10, the DFPI settled with a Los...more

OCC Prevails in Challenge to “Valid When Made” Rule

On February 8, the U.S. District Court for the Northern District of California ruled against three states – California, Illinois, and New York – challenging the OCC’s rule on the “valid when made” doctrine. In 2020, the OCC...more

New York Makes Remote Online Notarizations Permanent

On December 22, New York Governor, Kathy Hochul, signed Senate Bill 1780C (S1780C), which allows the state’s notaries to conduct remote online notarizations (RON). The law is to be effective on June 20, 2022. Among other...more

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