On January 14, 2025, the federal government sued Capital One, accusing it of deceptive practices related to its “360 Savings” accounts. Consumer Financial Protection Bureau v. Capital One Financial Corp., No. 25-cv-00061...more
On January 14, 2025, the CFPB filed a lawsuit against the Bank, alleging violations of the CFPA, TISA, and its implementing Regulation DD. The lawsuit alleges that the Bank deceived customers who were enrolled in the Bank's...more
On 18 September 2024, the FCA provided an update on its work in the cash savings market. Following the FCA’s 2023 cash savings market review in light of concerns that higher interest rates were not being passed on effectively...more
On May 7, 2024, the Consumer Financial Protection Bureau (CFPB) announced that it had entered into a consent order with a financial technology company, resolving allegations that the company committed unfair acts or practices...more
The CFPB published its Consumer Response Annual Report for 2023, which discusses the consumer complaints received by the CFPB in that year and how companies responded to those complaints. The CFPB monitors consumers’...more
The IRS and the U.S. Department of Labor recently issued guidance which addresses the newly created Pension Linked Emergency Savings Accounts (“PLESAs”), a novel plan design option authorized under SECURE 2.0. PLESAs are...more
On 31 July 2023, following roundtable discussions held with banks earlier that month, the FCA published its Cash Savings Market Review (the “Review”). In this insight we explore the content of the Review, as well as...more
On July 27, the Consumer Financial Protection Bureau (CFPB) released a new blog post, positing that cashflow data, broadly defined as the various inflows, outflows, and accumulated amounts in a consumer’s checking and savings...more
The CFPB is shifting its focus to FinTech and nonbank payment systems, circling back to past frontiers. This recent warning echoes the sentiment of former CFPB’s Director, Richard Cordray, focusing heavily on FinTechs and...more
The California Unruh Act (specifically, California Civil Code § 51) prohibits “all business establishments of every kind whatsoever” from discriminating based on citizenship or immigration status, among other things. That...more
If you poll a sampling of PEO and staffing community leadership, you’d probably discover that compliance with employee benefits law (not to mention the related insurance and tax fields) is among the most challenging and least...more
SECURE 2.0 created “pension-linked” emergency savings accounts, a new type of short-term savings program integrated within a 401(k) or other individual account plan. In this edition of our SECURE 2.0 webinar series, Groom...more
Following the initial flurry of publications summarizing the retirement plan enhancements under the SECURE 2.0 Act of 2022 (“SECURE 2.0”), this post takes a deeper dive into one of those enhancements: the optional...more
The Consumer Financial Protection Bureau (“CFPB”) announced a proposed consent order on December 1 intended to address a scam engaged in by a company called Loan Doctor, as well as by the company’s founder, Edgar Radjabli....more
On February 14, 2022, BlockFi Lending LLC (BlockFi) settled charges with the SEC and state securities regulators for a total of $100 million in penalties. BlockFi was charged with a failure to register the offer and sales of...more
The Uniform Gifts to Minors Act (UGMA) and the Uniform Transfers to Minors Act (UTMA) are sometimes called the “granddaddies” of college savings accounts. Both allow parents to establish custodial accounts for a minor child,...more
La proposta - In data 30 luglio 2020, la Banca d’Italia ha avviato una consultazione pubblica sulle modifiche da apportare al “Regolamento sulla gestione collettiva del risparmio”....more
In Washington - The House will meet for a pro forma session on Monday and the full House is out of session next week. The Senate will reconvene on Monday and resume consideration of John Badalamenti to be United States...more
On May 13, 2020, the Consumer Financial Protection Bureau (CFPB) issued two sets of FAQs. The first set of FAQs is directed to providers of checking, savings, and prepaid accounts. The second set of FAQs is directed to...more
Effective April 24, 2020, the Federal Reserve amended Regulation D to remove the six-per-month limit on transfers or withdrawals from the definition of a “savings deposit.” The amendment is set forth in an interim final rule...more
On April 28, 2020, the Federal Reserve Board (FRB) published an interim final rule that amends Regulation D to aid consumers with cash flow, due to the COVID-19 pandemic. Specifically, the FRB has eliminated the six-per-month...more
The IRS has issued proposed regulations related to § 529A of the Internal Revenue Code (the “Code”), which allows a State (or its agency or instrumentality) to establish and maintain a tax-advantaged savings program under...more
For many students, this time of year signals the end of their high school careers and the beginning of the transition to college. With that transition, students and their families must address difficult issues, including how...more
I call myself the “most dangerous ERISA attorney in America” because I’m not afraid to express my opinion. So I’m going to say something that will irk a few people....more
Only a small fraction of those eligible for new savings accounts for people with disabilities are using them, according to disability advocates. If participation doesn’t pick up – either through better promotion or...more