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CFPB Continues Lawsuit Over Alleged Military Lending Act Violations

On March 1, and despite recent policy shifts under the new administration, the CFPB sent a letter to the judge overseeing its lawsuit against a fintech lender in the United States District Court for the Southern District of...more

FDIC Withdraws Support for Colorado’s Opt-Out Law Before Tenth Circuit

On February 26, the FDIC withdrew its amicus brief in the 10th Circuit Court of Appeals challenging Colorado’s 2023 opt-out law which aimed to restricting higher-cost online lending. The FDIC’s decision follows a shift in the...more

Class Action Certified Against Fintech Lender for Home Improvement Loans

In an order issued in January and made public on February 24, a judge in the United States District Court for the Northern District of California granted class certification to consumers alleging a fintech lender’s loan...more

Federal Court Pauses Open Banking Rule Litigation

On February 25, a federal judge in the United District Court for the Eastern District of Kentucky approved a joint motion between the CFPB and banking trade groups to pause litigation over the agency’s 1033 open banking rule....more

CFPB Drops Lawsuit Against Online Lender Following Litigation Freeze

On February 23, the CFPB filed a joint stipulation in the United District Court for the Central District of California to dismiss its lawsuit against an online lending platform. The lawsuit, originally filed in May 2024,...more

CFPB Pauses Supervision Order, Signals Potential Rescission

On February 8, the CFPB requested a 90 day stay in a lawsuit filed by a major tech company challenging the agency’s risk-based supervision order. The lawsuit, filed in the U.S. District Court for the District of Columbia,...more

New FDIC Chairman Outlines Agency’s New Priorities

The FDIC will shift its focus and priorities under the leadership of its new Acting Chairman, Travis Hill. In a statement released on January 20, 2025, Chairman Hill signaled a potential departure from some of the initiatives...more

Trade Group Calls for Clarity on Ohio Fintech Guidance

On January 14, 2025, the American Fintech Council (AFC) submitted a letter to the Ohio Department of Financial Institutions, urging it to re-examine its recent guidance on responsible bank partnerships and provide more...more

CFPB Proposes Interpretive Rule on Emerging Payment Mechanisms Under EFTA

On January 2, 2025, the Consumer Financial Protection Bureau (CFPB) proposed an interpretive rule under the Electronic Fund Transfer Act (EFTA) and Regulation E to clarify how emerging payment systems, such as those used in...more

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

FTC and DOJ File Amended Complaint Against Cash Advance Fintech

On December 30, the Department of Justice (DOJ), at the Federal Trade Commission’s (FTC) referral, filed an amended complaint against an online cash advance provider. The complaint now names the company’s CEO as a defendant,...more

Fintech Industry Trade Associations Respond to Federal Regulators’ Joint RFI on Bank-Fintech Partnerships

On October 30, two leading fintech industry trade associations submitted comments (see comment letters here and here) in response to a joint Request for Information (RFI) issued by the Office of the Comptroller of the...more

Regulators Ramp up Scrutiny of Games’ Business Models

On August 28, the CFPB issued a Consumer Advisory warning that it believes video game companies are targeting children for monetary gain. With 45.7 million U.S. children engaged in video gameplay, the agency is concerned...more

The CFPB Continues to Reshape Consumer Protection in the Digital Arena 

On August 28, the CFPB issued a Consumer Advisory warning that it believes video game companies are targeting children for monetary gain. With 45.7 million U.S. children engaged in video gameplay, the agency is concerned...more

Federal Regulators Issue Joint Statement and Request for Information Emphasizing Caution with BaaS Model

On July 25, federal regulators issued a joint statement to further put banking organizations on notice of the inherent risks of collaborating with fintechs in offering deposit products and services. This guidance aims to...more

Lease-to-Own Fintech Sues the CFPB, Claiming it’s Unconstitutional 

On July 22, a Texas-based lease-to-own company filed suit against the CFPB in Federal District Court for the Eastern District of Texas alleging that its “illegal and unconstitutional investigation” into the company’s business...more

Oklahoma Bank Faces FDIC Consent Order

An Oklahoma-based bank has been hit with a consent order from the FDIC after posting significant losses in its first year of operation. On June 28, the FDIC announced that it took an enforcement action against the bank...more

Federal Reserve Board Issues Cease and Desist Order Against Banking-As-A-Service Provider

On June 14, the Federal Reserve Board (Fed) released a cease and desist order against an Arkansas-based banking-as-a-service (BaaS) provider for compliance and risk management failures. As part of the order, the bank is...more

Maryland Banking Regulator Settles with Bank/Fintech Partnership For Unlicensed Lending, Credit Repair, and Debt Collection...

On May 16, the Maryland Office of Financial Regulation (“OFR”) announced a settlement with a Missouri-based bank and its fintech partners for engaging in unlicensed lending, credit repair, and debt collection activities....more

Massachusetts AG Forces Fintech from State as Part of “True Lender” Settlement

On May 21, the Massachusetts Attorney General entered into an Assurance of Discontinuance (“AOD”) with a California-based fintech alleging that it was the “true lender” of its consumer installment loans. Under the terms of...more

CFPB Sues Fintech for Deceptive Practices Surrounding Tipping Service

On May 17, the CFPB filed a lawsuit against a California-based fintech that operates a nationwide website and mobile-application based peer-to-peer lending platform through which consumers can obtain small-dollar, short-term...more

Takeaways From the FDIC’s Spring 2024 Consumer Compliance Supervisory Highlights

On March 28, the FDIC released the spring edition of its consumer compliance supervisory highlights. The FDIC supervises approximately 3,000 state-chartered banks and thrifts that are not members of the Federal Reserve...more

Fed Brings Enforcement Action Against Wyoming Bank Holding Company Over “Fintech Business Strategy”

On March 28, the Federal Reserve (Fed) issued a cease-and-desist order to a Wyoming-based bank holding company, citing deficiencies identified in a September 2023 inspection related to its “fintech business strategy, board...more

FDIC Issues Orders Against Two More Banks Over Fintech Partnerships

In the FDIC’s latest monthly update on enforcement decisions and orders, the agency published recent consent orders it entered against both a New York-based and an Ohio-based bank, the latest in the agency’s series of...more

Washington State Passes New “True Lender” Legislation

On March 25, Washington State became the latest in a growing list of jurisdictions to introduce a “true lender” law with the passing of bill SB 6025. The legislation, similar to laws in other states would characterize a...more

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