On February 15, 2022, the Consumer Financial Protection Bureau (CFPB) issued a compliance bulletin indicating that it will be scrutinizing prepaid card providers who distribute government benefits and payments. Specifically,...more
The Consumer Financial Protection Bureau (CFPB) has released a compliance bulletin and policy guidance reminding debt collectors that attempting to collect on or furnishing information to consumer reporting agencies regarding...more
The Federal Reserve Board recently released a discussion paper and is seeking public comments on the potential benefits and risks, and related policy considerations, of introducing a central bank digital currency (CBDC) in...more
On January 26, 2022, the Consumer Financial Protection Bureau announced a request for information seeking comments related to fees charged to consumers in connection with selected products or services. The CFPB expressed...more
The Consumer Financial Protection Bureau (CFPB) has remained busy as we head into the final week of 2021. The agency released updated FAQs regarding the Electronic Fund Transfer Act (EFTA) and Regulation E, issued orders to...more
The Consumer Financial Protection Bureau (CFPB) released a statement on October 21, 2021, announcing that it has ordered six of the largest US technology companies that operate payment systems to turn over information about...more
The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued Sanctions Compliance Guidance for the Virtual Currency Industry. The guidance published on October 15, 2021, outlines OFAC’s...more
On September 1, 2021, the Consumer Financial Protection Bureau (CFPB) issued a notice of proposed rulemaking (NPRM) requesting public comment on its proposed rule to implement Section 1071 of the Dodd-Frank Wall Street Reform...more
Innovative companies and platforms that seek to bring new virtual currency products and services to market in the US generally need to consider the potential applicability of US state money transmission licensing laws. How...more
On August 31, 2021, a federal district court judge in Texas granted summary judgment to the Consumer Financial Protection Bureau in a lawsuit brought by two industry trade associations, ultimately upholding the “payment...more
On June 30, 2021, President Joe Biden signed a joint resolution to revoke the Office of the Comptroller of the Currency’s (OCC) “true lender” rule (the “Rule”). Passed in October 2020, the Rule clarified that a national bank...more
The California Department of Financial Protection and Innovation (DFPI) has finally adopted final rules relating to the scope of the agent-of-a-payee exemption under the California Money Transmission Act (MTA), Cal. Fin. Code...more
Any company that intermediates payments for other parties ─ such as a marketplace platform, a billing service, a payment facilitator or a B2B platform provider ─ must take into consideration the applicability of money...more
The US Consumer Financial Protection Bureau continues to focus on fair lending and is poised to increase enforcement actions. On March 9, the CFPB issued an interpretive rule to clarify that the prohibition against sex...more