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Eversheds Sutherland (US) LLP

Dual registrant regulatory roundup - July 2025

Welcome to the Regulatory Roundup. Each month, Eversheds Sutherland Investment Services attorneys review significant regulatory developments (including notable rulemakings and guidance from securities regulators) from the...more

Sheppard Mullin Richter & Hampton LLP

DFPI Finalizes $300,000 Settlement with Crypto Kiosk Operator for Alleged Digital Asset Law Violations

On June 25, the California DFPI announced that it had finalized a consent order with a cryptocurrency kiosk operator, alleging violations of the Digital Financial Assets Law (DFAL) and the California Consumer Financial...more

Goodwin

Connecticut Enacts Law Regulating Earned Wage Access Services

Goodwin on

Connecticut has enacted a law (the amendment) amending the state’s existing small loan act (the act). In this alert, we focus on the amendment’s application of the act to “earned but unpaid wage or salary income advances”...more

Orrick, Herrington & Sutcliffe LLP

Rhode Island enacts new virtual currency kiosk provisions

On June 23, the governor of Rhode Island signed into law HB 5121 which grants Rhode Island new currency transmission laws to regulate and establish new licensing, disclosure and anti-fraud requirements for virtual currency...more

Troutman Pepper Locke

Texas Enacts New Commercial Sales-Based Financing Bill Severely Restricting Automatic Debits

Troutman Pepper Locke on

On June 20, the Texas Legislature passed H.B. 700, which introduces several new regulatory requirements for providers and brokers of commercial sales-based financing operating within the state. The law applies to merchant...more

A&O Shearman

FCA publishes final rules on UK PISCES sandbox arrangements

A&O Shearman on

The UK Financial Conduct Authority (FCA) has published final policy statement PS25/6, accompanied by a press release, setting out the final rules for the Private Intermittent Securities and Capital Exchange System (PISCES)...more

Venable LLP

Why Fintechs Can't Always Skip the State Licensing Maze for Earned Wage Access

Venable LLP on

Earned Wage Access (EWA) lets employees access wages they've already earned, but haven't yet been paid, typically through an app or digital service. For workers, this can mean avoiding payday loans or overdraft fees....more

Mayer Brown

New York Enacts First-of-Its-Kind Law to License Buy-Now-Pay-Later Lenders

Mayer Brown on

The regulatory environment for “Buy Now, Pay Later” (or “BNPL”) loans is entering a new era. On May 9, 2025, New York enacted legislation that will require providers of BNPL loans to be licensed by the state and adhere to...more

Sheppard Mullin Richter & Hampton LLP

CFPB Drops Lawsuit Against Lease-to-Own Fintech Following Adverse Credit Ruling

On May 27, the CFPB filed a notice of dismissal with prejudice in its lawsuit against a lease-to-own fintech provider. The lawsuit, filed in July 2023, alleged that the company’s rental-purchase agreements violated several...more

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

Troutman Pepper Locke on

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

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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

A&O Shearman on

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

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

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

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

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