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The Earned Wage Access Boom: Sixteen States Propose Legislation to Regulate These Types of Products

Since the beginning of 2025, sixteen states have proposed legislation to regulate earned wage access. These states would join Kansas, Missouri, Nevada, South Carolina, and Wisconsin, which have each enacted legislation to...more

[Webinar] Deep Dives Presents: Open Banking - January 15th, 10:00 am PT

Join McGlinchey’s Deep Dives series for an in-depth exploration of open banking, a transformative trend reshaping financial services. This webinar will discuss the opportunities, challenges, and regulatory considerations of...more

Credit, Tips, Obligation to Pay: CFPB Proposed Interpretive Rule Seeks to Clarify Earned Wage Access and Regulation Z

On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued notice of a proposed interpretive rule (Rule) that walks back a prior 2020 Advisory Opinion on the manner in which Regulation Z defines “credit.” The...more

Deep Dive into Payments: Q&A on Bank Partnership Considerations

But upon closer consideration, there is an interplay between a bank partner program and the Electronic Fund Transfer Act (EFTA) as implemented by Regulation E, particularly when it comes to timeframes for disputes, liable...more

CFPB Proposes Expanded FCRA Reach – Will It Grab Your Business?

At a recent White House Roundtable, the Consumer Financial Protection Bureau’s (CFPB) Director, Rohit Chopra, announced that the bureau will promulgate new rules in September that will broaden the categories of...more

Video: Introduction: A Deep Dive into Payments

The world of payments has grown exponentially in recent years. The Consumer Financial Protection Bureau (CFPB) has continued its activity around Unfair or Deceptive Acts or Practices (UDAP), fees, and what the CFPB calls dark...more

SDNY: Crypto Regulated as “Funds,” Platforms as “Financial Institutions”

On February 22, 2023, the United States District Court for the Southern District of New York in Rider v. Uphold HQ Inc. held that cryptocurrencies constitute “funds” under the Electronic Fund Transfer Act (EFTA). The...more

FDIC Final Rule and its Impact on Bank Partnerships

On May 17, 2022, the Federal Deposit Insurance Corporation (“FDIC”) adopted a final rule establishing a new subsection B to the Federal Deposit Insurance Act (“FDIA”) addressing False Advertising, Misrepresentation of Insured...more

CFPB Launches New Office to Facilitate Competition and Innovation

On May 24, 2022, the Consumer Financial Protection Bureau (CFPB) announced that it is replacing the Office of Innovation with the newly-established Office of Competition and Innovation. The CFPB intends to “help spur...more

UDAAP And Fair Lending: When’s The Last Time You Reviewed Your Policies?

As expected, the change in presidential administrations is leading to a change in administrative policies. All consumer financial service providers who are subject to the jurisdiction of the Consumer Financial Protection...more

Credit Reporting During a Pandemic

Alert May 18, 2020 The economic impact of COVID-19 has already proven catastrophic for many businesses and consumers. Many employers are reducing their staffing or closing their doors permanently. As of May 8, 2020, the...more

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