News & Analysis as of

No-Action Letters FinTech

Holland & Knight LLP

SEC's New Crypto 2.0 Task Force Gets to Work

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On Feb. 4, 2025, SEC Commissioner Hester Peirce, in her role as head of the Commission's newly minted Crypto Task Force, provided additional detail regarding the task force's objectives. She began by managing expectations,...more

Clark Hill PLC

CFPB Reboots No-Action Letter and Sandbox Policies: A New Approach to Financial Innovation…Not

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On January 3, 2025, the Consumer Financial Protection Bureau (CFPB) announced a comprehensive reboot of its No-Action Letter (NAL) and Compliance Assistance Sandbox (CAS) policies. The proposed policies on its face, marks a...more

Ballard Spahr LLP

CFPB re-establishes regulatory sandbox, no-action letter programs

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In an effort to foster innovation in financial services, the CFPB is reinstituting its programs that allow companies to obtain regulatory safe harbors through no-action letters and sandboxes to test new products and services....more

Sheppard Mullin Richter & Hampton LLP

CFPB Updates No-Action Letter and Compliance Assistance Sandbox Policies to Spur Innovation

On January 3, 2025, the CFPB announced a reboot of its no-action letter and compliance assistance sandbox policy, aimed at promoting consumer-beneficial innovation in financial services. The new policies are designed to...more

Perkins Coie

Fintech Legal Report - July 2022

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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

Morrison & Foerster LLP

FinCEN Weighs Path to a No-Action Letter Process

On Friday, FinCEN published an Advance Notice of Proposed Rulemaking (ANPRM) as it further considers implementing a no-action letter process related to anti-money laundering compliance. The ANPRM follows a 2021 FinCEN...more

Perkins Coie

Fintech Week in Review - December 2020 #2

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House Financial Services Committee Sets Fintech Priorities for a New Administration - House Financial Services Committee Chairwoman Maxine Waters sent a letter to the incoming administration with nearly 50 pages of...more

Perkins Coie

Fintech Week in Review - November 2020

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FDIC Issues Operational Resilience Paper - In a new paper (here and here) the Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), and the Board of Governors of the Federal Reserve...more

Davis Wright Tremaine LLP

CFPB Introduces New No-Action Letter Templates

On May 22, 2020, the Consumer Financial Protection Bureau (CFPB) introduced two new No-Action Letter (NAL) "templates," described as part of the Bureau's ongoing efforts to both spur the introduction of new personal finance...more

Latham & Watkins LLP

INSIGHT: Crypto - The Pursuit of Sufficient Decentralization

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Recent SEC guidance on digital assets cleared a path for at least certain stable coins or payment tokens to avoid securities regulation. However, Latham & Watkins attorneys say there are still a number of open questions that...more

Ballard Spahr LLP

CFPB and Utah AG announce joint office hours in Salt Lake City as part of ACFIN

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The CFPB and Utah AG’s Office have announced that they will hold the first joint office hours as part of the American Consumer Financial Innovation Network (ACFIN).  The joint office hours will be held on January 30, 2020 in...more

Polsinelli

Wind of Change - The Year FinTech Came in From the Cold - Polsinelli BitBlog: Year End Edition

Polsinelli on

Digital assets and Blockchain technologies which were once described as the tools of criminals, are now a key part of efforts by traditional financial services firms to transform their businesses and innovative firms looking...more

WilmerHale

SEC No-Action Letter Opens the Door to Innovation for Securities Clearance and Settlement

WilmerHale on

On October 28, 2019, Paxos Trust Company, LLC (Paxos) received a time-limited (two-year) No-Action Letter from the Division of Trading and Markets of the U.S. Securities and Exchange Commission (SEC). This No-Action Letter...more

Ballard Spahr LLP

Paul Watkins, Director of the CFPB’s Office of Innovation, discusses final innovation policies in Ballard Spahr webinar

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Paul Watkins, Director of the CFPB’s Office of Innovation, joined Ballard Spahr partners Alan Kaplinsky and James Kim yesterday for a discussion of the CFPB’s final innovation policies.  ...more

Morgan Lewis

CFPB Revises Trial Disclosure Policy and Issues Compliance Assistance Sandbox Policy

Morgan Lewis on

In addition to releasing a finalized No-Action Letter (NAL) Policy, the Consumer Financial Protection Bureau (CFPB) also issued a revised Trial Disclosure Policy and Compliance Assistance Sandbox Policy on September 10....more

Morgan Lewis

CFPB Issues First No-Action Letter Under Newly Revised Policy

Morgan Lewis on

The Consumer Financial Protection Bureau (CFPB) finalized its revised No-Action Letter (NAL) Policy and issued its first NAL under the revised policy on September 10, in response to a request by the US Department of Housing...more

McDermott Will & Emery

SEC Division of Corporate Finance Issues Second No-Action Letter for a Blockchain Token Issuance

McDermott Will & Emery on

The SEC Division of Corporate Finance recently issued a no-action letter to Pocketful of Quarters, confirming that the Division will not recommend any enforcement action if the company sells its blockchain-based tokens...more

Nutter McClennen & Fish LLP

Fintech in Brief: CFPB Blog Updates First No-Action Letter Results

On August 4, 2019, the Consumer Financial Protection Bureau (“CFPB”) published a blog summarizing some of the results of simulations and analyses on an alternative data and credit model developed by Upstart Network, Inc....more

Nutter McClennen & Fish LLP

Fintech in Brief: SEC Staff Provides Additional Clarity on Digital Assets as Securities

Earlier this month, the Securities and Exchange Commission (“SEC”) provided additional guidance on digital assets, which include “tokens” and “coins.” The SEC’s Strategic Hub for Innovation and Financial Technology (“FinHub”)...more

Kilpatrick

State Attorneys General Criticize the CFPB’s Proposal to Create a Fintech Regulatory Sandbox and Revise its No-Action Letter...

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We have previously reported on the initiatives of the Consumer Financial Protection Bureau (CFPB or Bureau) to foster innovation in the fintech sector. In December 2018, the CFPB issued proposed revisions to its 2016 final...more

Nutter McClennen & Fish LLP

Fintech in Brief: Issues to Consider in Connection with the CFPB’s Proposed Product Sandbox and Policy Changes for No-Action...

Bank, nonbank, and Fintech providers of consumer financial products and services may be able to reduce their exposure to compliance risk under the December 13, 2018 No Action Letter (“NAL”) Policy changes proposed by the...more

Goodwin

Financial Services Weekly News - December 2018 #3

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Editor's Note - In This Issue. Federal financial regulators issues a proposed rule exempting community banks from the Volcker Rule; the Federal Deposit Insurance Corporation (FDIC) issued a notice of proposed rulemaking...more

Davis Wright Tremaine LLP

New CFPB Proposal to Overhaul Existing No-Action Letter Policy and Create a Federal Regulatory Sandbox

FinTech appears to be the next industry set to benefit from the Trump administration’s ongoing deregulatory push. The Bureau of Consumer Financial Protection’s (“Bureau”) long-gestating update to the Obama era no-action...more

Nutter McClennen & Fish LLP

Nutter Fintech in Brief: Bureau of Consumer Financial Protection Proposes Product Sandbox and Policy Changes for No-Action Letters

On December 13, 2018, the Bureau of Consumer Financial Protection (the “Bureau”), through its Office of Innovation, published two policy proposals consisting of (i) proposed changes to the Bureau’s Policy on No-Action Letters...more

Goodwin

Financial Services Weekly News - March 2018 #3

Goodwin on

Editor's Note - D.C. Circuit Strikes Down Key Pieces of FCC’s TCPA Interpretive Order. On March 16, the U.S. Court of Appeals for the D.C. Circuit issued its long-awaited decision in ACA International v. FCC, invalidating...more

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