In a significant move, on June 27, 2025 the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order granting banks and their subsidiaries an exemption from the Customer Identification...more
7/10/2025
/ Banks ,
Customer Identification Program (CIP) ,
Data Collection ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Patriot Act ,
Popular ,
Regulatory Reform ,
Regulatory Requirements ,
Taxpayer Identification Number ,
Third-Party ,
U.S. Treasury
Financial institutions have utilized service providers for a multitude of purposes over many years. The use of service providers has not historically been a controversial issue, and financial institutions have always had an...more
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
9/15/2023
/ Bank Partnership Lending Programs ,
Bank Secrecy Act ,
Board of Governors ,
Consumer Financial Protection Bureau (CFPB) ,
EFTA ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
FinTech ,
Non-Bank Lenders ,
Non-Depository Institutions ,
OCC ,
Regulation E ,
Risk Management ,
Third-Party ,
UDAAP
The next item in McGlinchey's Deep Dive into Payments Series is a podcast on money transmission by attorneys Jeff Barringer, Amy Greenwood-Field, and Aaron Kouhoupt. Their discussion centers around the impacts of money...more
8/28/2023
/ Cryptocurrency ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Licensing Rules ,
Money Services Business ,
Money Transmission Act ,
Money Transmitter ,
Payment Processors ,
The Model Law ,
Third-Party
The next item in McGlinchey’s Deep Dive into Payments Series is on money transmission by attorneys Jeff Barringer, Amy Greenwood-Field, and Aaron Kouhoupt. Their discussion centers around the impacts of money transmission...more
8/28/2023
/ Cryptocurrency ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Licensing Rules ,
Money Services Business ,
Money Transmission Act ,
Money Transmitter ,
Payment Processors ,
The Model Law ,
Third-Party