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CFPB Calls for Complaints About Marketplace Lenders

On March 7, 2016, the Consumer Financial Protection Bureau (“CFPB”) made its first official moves on “marketplace lending,” which also may be known as “peer-to-peer” lending. The CFPB described marketplace lending as the use...more

CFPB Publishes No-Action Letter Policy Statement

On February 22, 2016, the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) published its Final Policy Statement (“Final Policy”) on No-Action Letters (“NALs”). The Final Policy follows a Proposed Policy on...more

Are You a “Payment Processor”? Washington State Appears to Significantly Expand Scope of Its Money Transmission Act

One of the defining aspects of the payments revolution of the past few years—at least from a regulatory perspective—has been the question of whether any particular payments service is subject to regulation as money...more

CFPB Takes Action Against Lead Aggregators

On December 17, 2015, the Consumer Financial Protection Bureau (“CFPB”) announced that it has taken action against lead aggregators that resold sensitive personal information to lenders and debt collectors. In a complaint...more

Loan to San Bernardino Attacker Generates New Focus on Online Marketplace Lending and Terrorism Financing

News that an online marketplace lender extended a $28,500 loan to Syed Rizwan Farook, one of the alleged San Bernardino attackers, just two weeks before the attack, has spurred House Financial Services Committee Chairman Jeb...more

The CSBS Finalizes Model Framework for Virtual Currencies

On September 15, 2015, the Conference of State Bank Supervisors (“CSBS”) issued its final Model Regulatory Framework on virtual currency activities (“Final Framework”). The Final Framework follows the CSBS’s December 2014...more

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