On July 27, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, the agencies) issued a joint notice of proposed...more
On July 7, Missouri Governor Mike Parson signed SB 103 into law, which prohibits any person from offering earned wage access (EWA) services without registering with the Division of Finance and paying an annual $1,000 fee. The...more
7/13/2023
/ Consumer Financial Products ,
Credit Reports ,
Credit Scores ,
Earned Wage Access ,
Electronic Fund Transfer Act ,
Financial Services Industry ,
New Legislation ,
Payday Lending Rule ,
Popular ,
Regulatory Requirements ,
Wage and Hour ,
Wages
Please join Troutman Pepper attorneys Chris Willis, Keith Barnett, Carlin McCrory, and Josh McBeain in announcing the Payments Pros Podcast — our new podcast providing insights for those in the payments law industry. This...more
In this episode of Payments Pros, our hosts Keith Barnett, Carlin McCrory, and Josh McBeain join their colleague Chris Willis to discuss the Consumer Financial Protection Bureau's (CFPB) larger participant rule for consumer...more
Please join Troutman Pepper Partner Chris Willis and colleagues Keith Barnett, Carlin McCrory, and Josh McBeain as they discuss the Consumer Financial Protection Bureau's (CFPB) larger participant rule for consumer payments...more
On June 15, Nevada Governor Joe Lombardo signed SB 290 into law, which imposes licensing, reporting, examination, and other substantive requirements on providers of earned wage access (EWA) products. Specifically, the...more
This edition of Payments Pros spotlights an episode from The Crypto Exchange podcast where Ethan Ostroff sat down with Payments Pros hosts Keith Barnett and Carlin McCrory to discuss recent developments with convenience fees...more
On June 20, the Consumer Financial Protection Bureau’s (CFPB or Bureau) Office of Servicemember Affairs published its Annual Report analyzing complaints submitted by servicemembers, veterans, and their families in 2022. The...more
6/22/2023
/ Annual Reports ,
Consumer Complaint Management ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Federal Trade Commission (FTC) ,
Financial Fraud ,
Financial Services Industry ,
Military Service Members ,
Mobile Apps ,
Regulation E ,
UDAAP
The Consumer Financial Protection Bureau (CFPB or Bureau) has signaled that it intends to propose a rule that would allow it to exercise supervisory authority over a greater number of nonbank financial companies that...more
Troutman Pepper’s Payments Pros podcast offers insights from Troutman Pepper Fintech and Payment practice group attorneys, industry business leaders, and regulatory experts on the most challenging legal and regulatory...more
The Federal Trade Commission (FTC) has reached a settlement with Nexway, Inc. (Nexway), its affiliated companies, and officers for allegedly facilitating tech support scams in violation of Section 5 of the FTC Act and the...more
On April 5, the Federal Deposit Insurance Corporation (FDIC) released its Consumer Compliance Supervisory Highlights report, providing a high-level overview of consumer compliance issues identified by the agency during 2022...more
On February 22, New York Attorney General Letitia James filed an enforcement action against digital asset exchange, CoinEx, for failing to register as a securities and commodities broker-dealer and for falsely representing...more
In the fourth and final segment of our four-part Crypto Year in Review series, Ethan Ostroff, Keith Barnett, and Carlin McCrory discuss how the U.S. Treasury Department — including the Office of Foreign Asset Control (OFAC)...more
In the third segment of our four-part Crypto Year in Review series, Ethan Ostroff, Keith Barnett, and Addison Morgan discuss state-level regulation of interest-bearing cryptocurrency deposit products. Our speakers explain...more
As discussed here, on September 8, 2022, an en banc panel of the Eleventh Circuit Court of Appeals reversed the district court’s decision that a debt collector’s outsourcing of its letter process to a third-party mail vendor...more
On February 23, The Board of Governors of the Federal Reserve System (the Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the Agencies) issued a...more
In a letter dated February 10, the American Bankers Association (ABA), Consumer Bankers Association (CBA), Credit Union National Association (CUNA), National Association of Federally‐Insured Credit Unions (NAFCU), and The...more
In the first of a four-part Crypto Year in Review series, Carlin McCrory, Keith Barnett, and Ethan Ostroff look at how the CFPB and FTC viewed and regulated cryptocurrency in 2022. The panel examines statements by CFPB...more
On January 27, the Federal Reserve Board (Fed) announced that it denied the application of Custodia Bank, a Wyoming special purpose depository institution (SPDI), for member status on the basis that its novel business model...more
The Federal Deposit Insurance Act (FDIA) generally prohibits insured state banks, but not uninsured state member banks, from acting as principal in activities that are not permissible for national banks. Relying on its...more
On January 3, The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (the Agencies) issued a joint statement to banking organizations...more
On December 14, Senators Elizabeth Warren (D-Mass.) and Roger Marshall (R-Kan.) introduced the Digital Asset Anti-Money Laundering Act of 2022 (the Act) that would extend anti-money laundering and countering of the financing...more
The Consumer Financial Protection Bureau (CFPB) issued a decision denying Nexo Financial, LLC’s petition to modify a civil investigation demand (CID) originally served on the company on December 1, 2021. At that time, Nexo...more
On November 28, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $362,158.70 settlement with Payward, Inc. d/b/a Kraken. The Delaware-incorporated virtual currency exchange allegedly...more