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Disclosure Requirements FinTech

A&O Shearman

IOSCO publishes final reports on finfluencers, online imitative trading practices and digital engagement practices

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The International Organization of Securities Commissions (IOSCO) has published final reports on finfluencers, online imitative trading practices and digital engagement practices, accompanied by a press release. These reports...more

Goodwin

Maryland Enacts Law Regulating Earned Wage Access Services

Goodwin on

Maryland has enacted a law that establishes a financial-services oversight regime for earned wage access services, also known as on-demand pay services, which allow workers to access earned but unpaid income before payday....more

Payactiv

Maryland Enacts Landmark Earned Wage Access Legislation

Payactiv on

On May 27, 2025, Maryland enacted first-of-its-kind earned wage access (EWA) legislation to ensure Maryland workers are able to retain continued access to this valuable employee benefit. This landmark legislation follows...more

Ballard Spahr LLP

New York Gov. Hochul signs legislation that includes BNPL Licensing Requirements and other Consumer Protection Provisions

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New York Gov. Kathy Hochul has signed legislation that, among other things, imposes new licensing requirements on Buy Now, Pay Later services....more

Orrick, Herrington & Sutcliffe LLP

Arizona enacts law regulating crypto asset kiosk operators

On May 12, the Arizona Legislature enacted HB 2387 which creates new fraud prevention requirements for cryptocurrency kiosk operators doing business in the state. The law requires cryptocurrency kiosk operators to, among...more

Troutman Pepper Locke

Welcoming a New Payment Pro: Jason Cover Joins the Payments Pros Podcast — Payments Pros – The Payments Law Podcast

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In this episode of Payments Pros, Carlin McCrory introduces Jason Cover as a new co-host. Jason, a partner in Troutman Pepper Locke's Consumer Financial Services practice, brings extensive knowledge in consumer lending and...more

Klein Moynihan Turco LLP

Major Crypto Sweepstakes Lawsuit Settlement Announced

Earlier this week, Coinbase and its sweepstakes administrator agreed to the terms of a class action settlement in the matter of Suski v. Coinbase, Inc. After nearly four years of litigation, including a trip to the United...more

Goodwin

Indiana Enacts Law Regulating Earned Wage Access Services

Goodwin on

Indiana has enacted a law that establishes a financial-services oversight regime for earned wage access services, also known as on-demand pay services, which allow workers to access earned but unpaid income before payday....more

Wilson Sonsini Goodrich & Rosati

SEC’s Division of Corporation Finance Issues Views on Disclosure for Securities in Crypto Asset Markets

On April 10, 2025, the SEC’s Division of Corporation Finance (Corp Fin) issued a statement expressing its views about the application of certain disclosure requirements under the federal securities laws to offerings and...more

GeoDataVision

Potential Improvements for CRA (Part 4c of 4)

GeoDataVision on

In the previous articles of this 4-part series, I identified and explained three types of fatal flaws in the 2023 CRA rule and I presented 5 suggestions to improve the effectiveness of the legacy CRA rule. In this article I...more

A&O Shearman

FCA findings on multi-firm review of trading apps

A&O Shearman on

The UK Financial Conduct Authority (FCA) has published a webpage summarising the findings from its multi-firm review of trading apps, together with a press release. The FCA notes that this is a growing sector allowing more...more

Mayer Brown

Arkansas and Utah Enact Laws to Regulate Earned Wage Access Providers

Mayer Brown on

Just days apart, Arkansas and Utah enacted laws to regulate providers of earned wage access (“EWA”) services, joining the handful of states that have enacted legislation to regulate these products since 2022. Arkansas House...more

A&O Shearman

FCA update on PISCES and pre-application support

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The UK Financial Conduct Authority (FCA) has published an update on the Private Intermittent Securities and Capital Exchange System (PISCES) sandbox, following the consultation in December 2024 (CP24/29). PISCES will be a new...more

DLA Piper

SEC Staff Observations on Compliance with Disclosure Requirements in Offerings and Registrations of Securities in the Crypto Asset...

DLA Piper on

On April 10, 2025, the staff of the Division of Corporation Finance of the US Securities and Exchange Commission (SEC) issued a statement (Staff Statement) expressing its observations regarding certain disclosure requirements...more

Sheppard Mullin Richter & Hampton LLP

Utah and Arkansas Enact Earned Wage Access Regulations

Utah and Arkansas have enacted new legislation governing earned wage access (EWA) services, establishing state-level registration obligations and consumer protection standards. Both laws clarify that EWA services are not...more

Venable LLP

Cleo AI Settles with FTC for $17 Million for Alleged Misleading Practices and Autorenewal Violations

Venable LLP on

In one of the first settlements since the new administration took office, the Federal Trade Commission (FTC) announced a $17 million monetary judgment with Cleo AI to resolve allegations that Cleo violated Section 5 of the...more

A&O Shearman

ESMA guidelines on suitability requirements and format of the periodic statement for portfolio management activities under MiCAR

A&O Shearman on

Official translations of the guidelines on certain aspects of the suitability requirements and format of the periodic statement for portfolio management activities under the EU Markets in Crypto Assets Regulation (MiCAR) have...more

Goodwin

Want to Have Customers Cover Payment Processing Fees? What You Need to Know About Credit Card Surcharging

Goodwin on

Credit card surcharging is on the rise. Imposing a surcharge in a compliant manner is more than adding a fee at the point of sale. Below we review on a high level the legal and commercial considerations for merchants before...more

Latham & Watkins LLP

FCA Publishes 5-Year Strategy and Outcome of Rule Review

Latham & Watkins LLP on

FCA outlines its priorities and areas in which it plans to reduce the regulatory burden for firms. On 25 March 2025, the FCA published its five-year strategy (Strategy), alongside the outcome of its review of retail conduct...more

McGuireWoods LLP

Utah to Join Other States Enacting Legislation to Regulate Earned Wage Access

McGuireWoods LLP on

Upon signature by Gov. Spencer Cox, Utah will join five other states in enacting a law that specifically regulates earned wage access (EWA) providers as nonlenders....more

Fenwick & West LLP

Rollback of DeFi Reporting Regs Advances Through Congress

Fenwick & West LLP on

On March 4, 2025, the U.S. Senate passed joint resolution S.J.Res.3, disapproving the DeFi broker reporting regulations Treasury finalized at the end of the Biden Administration. Senator Ted Cruz (R-TX) introduced the...more

Jones Day

Regulating Digital Assets: FIT21 Seems to Fit the Bill

Jones Day on

The United States lacks a regulatory framework geared toward digital assets. This raises consumer protection concerns, causes regulatory turf battles and duplicative enforcement actions, impedes innovation, and puts the...more

Orrick, Herrington & Sutcliffe LLP

Fintech reaches consent order with CFPB over regulatory violations, deceptive practices

On January 30, the CFPB issued a consent order against a fintech company that allows customers to send, receive and store remittances through a mobile app’s prepaid accounts and debit cards. The CFPB alleged the fintech...more

Cadwalader, Wickersham & Taft LLP

SEC Rescinds Crypto Interpretive Guidance That Has Hamstrung Industry

Effective January 30, the Securities & Exchange Commission ("SEC") rescinded the Staff Accounting Bulleting ("SAB") that has made engaging in crypto-related activities so perilous over the last couple of years, SAB-121,...more

Carlton Fields

SEC 2025 Examination Priorities Shine Light on AI

Carlton Fields on

Changes in available financial technology are changing the way the SEC’s Division of Examinations will examine registered firms. The division’s recently released 2025 examination priorities focus on the emerging risks posed...more

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