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Nonbank Firms

Venable LLP

CFPB Pauses Enforcement of Nonbank Registration Deadlines

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On April 11, 2025, the Consumer Financial Protection Bureau (CFPB) announced that it will not prioritize enforcement or supervisory actions against nonbank entities that miss upcoming registration deadlines under its Nonbank...more

Holland & Knight LLP

CFPB Provides Supervision and Enforcement Reprieve on Nonbank Registration Regulation

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In connection with its regulation titled Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders (the Nonbank Registration Regulation), the CFPB announced on April 11, 2025, that it "will not prioritize...more

Orrick, Herrington & Sutcliffe LLP

Congress overturns two CFPB rules via congressional review

On April 9, the House of Representatives passed two resolutions that it received from the Senate, overturning two CFPB rules from the Biden administration. The House considered S.J. Res. 18, disapproving the CFPB’s final rule...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: A Debate About The Need, If Any, For a Federal Charter for Non-Banks Engaged in the...

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Our podcast show today features Professor Dan Awrey of Cornell Law School, and Matt Lambert, Deputy General Counsel of the Conference of State Bank Supervisors (“CSBS”) who discuss the pros and cons of Congress enacting a...more

Orrick, Herrington & Sutcliffe LLP

Prudential regulators release 2024 Shared National Credit report

On March 10, the FDIC, the Fed and the OCC published the 2024 Shared National Credit Program (SNC) report which highlighted that the overall SNC credit risk remains moderate — with a slight increase in the severity of risk...more

Goodwin

2024 Year in Review: Fintech

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Financial technology — or fintech — companies will continue to receive increased regulatory scrutiny in 2025. The latter half of 2024 saw a rise in regulatory guidance and enforcement activity relating to fintechs and the...more

Ballard Spahr LLP

Senate adopts CRA resolution to nullify rule subjecting large cash apps to bureau supervision

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Using the Congressional Review Act, the Senate has voted to nullify a CFPB final rule that would subject large cash apps to the bureau’s supervision....more

Mayer Brown

What to Expect in Licensing in 2025

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With the currently revolving door of directors at the federal Consumer Financial Protection Bureau (CFPB)—which may soon be on its fourth director in 2025 alone—and an order issued by Acting CFPB Director Russell Vought to...more

A&O Shearman

Financial Stability Board publishes work program for 2025

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The Financial Stability Board has published its work program for 2025. Priority areas of work for 2025 include: - supporting global cooperation on financial stability: the FSB will continue monitoring global financial...more

Hudson Cook, LLP

CFPB Settles with Peer-to-Peer Payment App Company for Allegedly Failing to Prevent Fraud and Investigate Disputes

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On January 16, 2025, the CFPB announced that it issued a stipulation and consent order against the Company, to resolve allegations that the Company violated the CFPA, the EFTA, and Regulation E....more

Goodwin

51 State Financial Regulatory Agencies Enter Settlement and Consent Order with Nonbank Mortgage Servicing Companies

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​​​​​​​​On January 9, 2025, 51 State Financial Regulatory Agencies (the “Agencies”) announced a coordinated consent order and settlement agreement with nonbank mor​tgage servicing companies (the “Companies”). ...more

Sheppard Mullin Richter & Hampton LLP

CFPB Announces Plans to Regulate Nonbank Personal Loan Providers

On January 8, the CFPB announced its intent to pursue rulemaking that would allow the agency to oversee nonbank personal loan lender. The announcement came in response to a petition filed in September 2022 by the Consumer...more

Barnea Jaffa Lande & Co.

Applicability of Payment Services and Initiation of Payment Law in Trust Frameworks

The Israel Securities Authority recently published a legal staff position aimed at clarifying the applicability of the Payment Services and Payment Initiation Regulation Law to activities conducted within trust/escrow...more

DLA Piper

CFPB Issues New Rule Addressing Supervision of Nonbank Payment Providers

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The Consumer Financial Protection Bureau (CFPB) has issued a new rule addressing its supervision of large nonbank companies offering US consumers certain digital funds transfer services and payment wallets and apps....more

Alston & Bird

Payments Docket – December 2024

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The latest edition of the Payments Docket, our roundup of key litigation and enforcement involving the payments industry, features why the CFPB’s open banking rule is under fire, a convenience fee that steals your lunch...more

Barnea Jaffa Lande & Co.

Salary payments in Israel through payment companies

An amendment to the Israeli Wage Protection Law was included in the secondary amendments to the Regulation of Payment Services and Payment Initiation Law. This legislative amendment enables employees to request that their...more

Venable LLP

CFPB Expands Oversight: Finalizes New Rule Targeting Big Players in Digital Payments

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On November 21, the Consumer Financial Protection Bureau (CFPB) finalized a rule to supervise nonbank companies that offer digital wallets and payment apps. The rule allows the CFPB to supervise and examine nonbank companies...more

Nutter McClennen & Fish LLP

Nutter Bank Report: November 2024

The CFPB has adopted a final rule to extend its oversight to the largest nonbank providers of digital consumer payment applications, including those that enable transfers from deposit accounts held at banks and other insured...more

Holland & Knight LLP

CFPB Finalizes New Federal Supervision of Certain Providers of Digital Wallets, Payment Apps

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The Consumer Financial Protection Bureau (CFPB) on Nov. 21, 2024, issued a final rule to supervise larger nonbank companies that offer "general-use digital consumer payment applications" such as digital wallets, payment apps...more

Alston & Bird

CFPB Releases Chart to Help Determine if Nonbank Registration is Required

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What Happened? On October 3, 2024, the CFPB released a Nonbank Registration: Orders Rule Coverage Chart (the “Chart”) that summarizes how  an entity that is subject to an order may determine if it must register that order...more

Kaufman & Canoles

K&C Sports & Entertainment Law Weekly Roundup - October 2024 #5

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A federal judge late Wednesday ordered the U.S. Department of Veterans Affairs to lock down UCLA’s Jackie Robinson Stadium on the VA’s West Los Angeles campus at noon Thursday until the university comes up with a proposal for...more

Troutman Pepper Locke

FDIC Publishes Proposed Rule on Recordkeeping for Third-Party Deposits, Opens Comment Period

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We previously posted on the Federal Deposit Insurance Corporation’s (FDIC) notice of proposed rulemaking aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank companies....more

Venable LLP

Navigating the CFPB’s Nonbank Enforcement Action Registry Coverage and Deadlines

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It may be a familiar role for legal and compliance teams to advise on and implement compliance decisions related to registrations, but that doesn't mean the upcoming deadlines for complying with the first-of-its-kind CFPB...more

Troutman Pepper Locke

Georgia Grants Fiserv a Special Banking Charter: A Major Milestone for Fintech and Nonbank Direct Access to Card Networks

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In a significant development since our last post, Fiserv’s application for a merchant acquirer limited purpose bank (MALPB) charter has been approved by the Georgia Department of Banking and Finance. This approval marks a...more

Ballard Spahr LLP

FDIC Issues Notice of Proposed Regulations for Enhanced Recordkeeping for Third-Party Custodial Accounts

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On September 17, 2024, the FDIC board approved a notice of proposed rulemaking that would increase recordkeeping obligations for bank deposits received from third party, non-bank companies that accept those deposits on behalf...more

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