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Synapse Failure Spurs FDIC To Specify Record Keeping for Bank Sponsored Fintechs

The Federal Deposit Insurance Corporation (“FDIC”) proposed in its Notice of Proposed Rulemaking (“NPR”) that insured IDIs keep records of individual accounts that are typically held in pooled custodial accounts that support...more

CFPB Applies Consumer Credit Card Protections to Buy Now, Pay Later Plans

Buy Now, Pay Later (“BNPL”) payments are often presented by retailers and BNPL lenders to consumers as an alternative to traditional credit card payments. After close scrutiny of industry practices for several years, the...more

Open Banking: When You Build It, Will They Come? CFPB Proposes Rules Requiring Banks to Share Consumer Data

The federal consumer protection agency’s proposed rule would give consumers greater control over access to their personal financial information held by banks and credit unions. The CFPB’s stated goal is to increase...more

The Corporate Transparency Act (CTA) is Coming: Creation of a U.S. National Beneficial Ownership Database

Potentially as soon as late 2022 or early 2023, a new U.S. regulatory requirement will come into effect which will affect over 25 million existing business entities and another 3-4 million new entities each year. The...more

Compliance Impact of FinCEN Statement of Priorities

At the direction of the President, FinCEN is intensifying its regulation of banks and fintechs across the spectrum of the laws that it is charged with enforcing. This past June, the White House published the Memorandum on...more

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