Connecticut has enacted a law (the amendment) amending the state’s existing small loan act (the act). In this alert, we focus on the amendment’s application of the act to “earned but unpaid wage or salary income advances”...more
7/10/2025
/ Amended Legislation ,
Borrowers ,
Consumer Lenders ,
Consumer Protection Laws ,
Disclosure Requirements ,
Earned Wage Access ,
Financial Services Industry ,
FinTech ,
Lenders ,
New Legislation ,
Regulatory Requirements ,
Unpaid Wages ,
Wage Advances
Louisiana has enacted a law that establishes a financial services oversight regime for earned wage access services, also known as on-demand pay services, which allow workers to access earned but unpaid income before payday....more
Maryland has enacted a law that establishes a financial-services oversight regime for earned wage access services, also known as on-demand pay services, which allow workers to access earned but unpaid income before payday....more
Utah has become the seventh state (and the second in 2025) to enact a law that establishes a financial services oversight regime for earned wage access services, also known as on-demand pay services, which allow workers to...more
Arkansas has become the sixth state (and the first in 2025) to enact a law that establishes a financial services oversight regime for earned wage access services, also known as on-demand pay services, which allow workers to...more
On January 1, 2025, Massachusetts Gov. Maura Healey approved House Bill No. 4840, which repeals and replaces Massachusetts’ money transmission law with a revised law (MTL Law), which is based in part on the model Money...more
1/17/2025
/ Amended Legislation ,
Banking Sector ,
Compliance ,
CSBS ,
Financial Services Industry ,
Licensing Rules ,
Money Transmission Act ,
Payment Systems ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements
On October 11, 2024, the California Office of Administrative Law approved the California Department of Financial Protection and Innovation’s (department) final regulations (rule) under the California Consumer Financial...more
South Carolina has become the fifth state (and the third in 2024) to enact a law that establishes a financial services oversight regime for earned wage access services, also known as on-demand pay services, which allow...more
5/23/2024
/ Annual Reports ,
Compliance ,
Consumer Financial Products ,
Earned Wage Access ,
Financial Services Industry ,
New Legislation ,
Office of Consumer Affairs ,
On-Demand Services ,
Registration Requirement ,
Regulatory Oversight ,
State Labor Laws ,
Wages
Kansas has become the fourth state (and the second in 2024) to enact a law that establishes a financial services oversight regime for earned wage access services, also known as on-demand pay services, which allow workers to...more
Following Nevada and Missouri in 2023, Wisconsin has become the third state (and the first in 2024) to enact a law that establishes a financial services oversight regime for earned wage access services, also known as...more
3/25/2024
/ Annual Reports ,
Compliance ,
Compliance Dates ,
Consumer Financial Products ,
Earned Wage Access ,
Fees ,
Financial Services Industry ,
Licensing Rules ,
Regulatory Oversight ,
Tips ,
Wages
Following closely behind Nevada, Missouri has become the second state to enact a law that establishes a financial services oversight regime for earned wage access services (also known as on-demand pay services), which allow...more
Nevada has become the first state to enact a law that establishes a financial services licensing regime for earned wage access services (aka on-demand pay services), which allow workers to access earned but unpaid income...more
The Consumer Financial Protection Bureau’s adopting release for its small business data collection and reporting rule goes beyond that rule by including a discussion deeming merchant cash advances to be “credit” more...more
Partnerships between financial technology companies (fintechs) and banks have revolutionized the financial services landscape. The convergence of technology and banking has resulted in financial products and services being...more
On February 1, 2023, the New York State Department of Financial Services (DFS) adopted final regulations relating to New York’s Commercial Finance Disclosure Law (CFDL), which requires providers of commercial financing,...more
In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more
12/10/2021
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Amended Rules ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Beneficial Owner ,
Broker-Dealer ,
BSA/AML ,
CFTC ,
Comment Period ,
Continuing Education ,
Coronavirus/COVID-19 ,
Corporate Transparency Act ,
FDIC ,
FFIEC ,
Final Rules ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
FinCEN ,
Foreign Corporations ,
Libor ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Proposed Rules ,
Public Comment ,
Real Estate Transactions ,
Recordkeeping Requirements ,
Registration Requirement ,
Regulation Z ,
Reporting Requirements ,
Secured Overnight Funding Rate (SOFR) ,
Securities and Exchange Commission (SEC)
In This Issue. The Treasury Department’s Financial Stability Oversight Council (FSOC) issued a report acknowledging climate change as threat to financial stability; Federal Reserve Governor Michelle Bowman advocates for...more
10/29/2021
/ Banking Sector ,
Climate Change ,
Community Banks ,
Community Reinvestment Act ,
Consumer Financial Protection Bureau (CFPB) ,
ETFs ,
Federal Reserve ,
Final Rules ,
Financial Services Industry ,
FSOC ,
Mutual Funds ,
OCC ,
Payment Systems ,
Regulation Z ,
Risk Alert ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury
In This Issue. President Biden signed a bill extending the Small Business Administration’s (SBA) Paycheck Protection Program (PPP) through May 31, 2021; the Consumer Financial Protection Bureau (CFPB) announced the rescission...more
4/2/2021
/ Artificial Intelligence ,
Automotive Industry ,
Biden Administration ,
Capital Requirements ,
Causation ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Dividends ,
Federal Reserve ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Agencies ,
Financial Services Industry ,
Ford Motor ,
Ford Motor Co. v Bandemer ,
Ford Motor Co. v Montana Eighth Judicial District Court ,
Jurisdiction ,
Paycheck Protection Program (PPP) ,
Payday Lending Rule ,
Personal Jurisdiction ,
Policy Statement ,
SBA ,
SCOTUS ,
Share Buybacks ,
Small Dollar Lenders ,
Stress Tests ,
Supervisory Guidance
In this Issue. The Consumer Financial Protection Bureau (CFPB) issued a statement announcing its intention to revisit Trump-era qualified mortgage (QM) final rules; the Biden Administration announced changes to the Small...more
2/26/2021
/ Banking Sector ,
Biden Administration ,
Board of Governors ,
Close-Ended Funds ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Rating Agencies ,
Current Expected Credit Losses (CECL) ,
Deposit Insurance ,
Disclosure Requirements ,
Exclusions ,
Fair Value Standard ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
Good Faith ,
Initial Public Offering (IPO) ,
Internal Controls ,
Mortgage Lenders ,
Mortgages ,
No-Action Letters ,
Paycheck Protection Program (PPP) ,
Proxy Materials ,
Qualified Mortgage Rule ,
SBA ,
Securities and Exchange Commission (SEC) ,
Shareholder Proposals ,
Special Purpose Acquisition Companies (SPACs)
In this Issue. The Office of the Comptroller of the Currency (OCC) delayed publication of the “fair access” rule finalized late in the Trump Administration; the OCC also announced the availability of the 2021 list of bank...more
2/9/2021
/ Banking Sector ,
Banks ,
California Consumer Financial Protection Law (CCFPL) ,
Community Reinvestment Act ,
Debt Collection ,
Debtors ,
Delays ,
Department of Financial Protection and Innovation (DFPI) ,
Fair Access to Credit ,
FDIC ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Paycheck Protection Program (PPP) ,
Proposed Rules ,
SBA ,
Securities Regulation ,
Trump Administration ,
Unfair or Deceptive Trade Practices
In this Issue. In one of its first acts after being installed on January 20, the Biden Administration issued a regulatory freeze on new agency rules that have been adopted but are not yet effective; in one of its final acts...more
1/29/2021
/ Anti-Money Laundering ,
Appeals ,
Banking Sector ,
Biden Administration ,
Borrowers ,
Carried Interest ,
Comment Period ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Debt Relief ,
Debtors ,
Digital Assets ,
Enforcement Actions ,
Fair Access to Credit ,
FDIC ,
Fees ,
Final Report ,
Final Rules ,
Financial Regulatory Agencies ,
Financial Services Industry ,
FinCEN ,
Internal Revenue Code (IRC) ,
Lenders ,
Misrepresentation ,
Mortgage Lenders ,
New Rules ,
OCC ,
Popular ,
Public Comment ,
Regulatory Freeze ,
Ripple ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Settlement Agreements ,
Student Loans ,
Supervisory Guidance ,
Suspicious Activity Reports (SARs) ,
Unlawful Practices ,
Unregistered Securities ,
Virtual Currency
In this Issue. The Securities and Exchange Commission (SEC) finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors, and published a risk...more
1/7/2021
/ Advisory Opinions ,
Appeals ,
Banking Sector ,
Broker-Dealer ,
Cash Solicitation Rule ,
Community Reinvestment Act ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
Fair Credit Reporting Act (FCRA) ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Interim Final Rules (IFR) ,
Interpretive Letters ,
Investment Adviser ,
Lenders ,
OCC ,
OCIE ,
Paycheck Protection Program (PPP) ,
Popular ,
Preemption ,
Proposed Rules ,
Recordkeeping Requirements ,
Regulation Z ,
Relief Measures ,
Reporting Requirements ,
Risk Alert ,
Safe Harbors ,
SAR ,
SEC Advertising Rule ,
Securities and Exchange Commission (SEC) ,
Securities Litigation ,
Securities Violations ,
Special Purpose Entities
In this Issue. The Federal Deposit Insurance Corporation (FDIC) was busy this week, finalizing rules that modernize brokered deposits regulations, establish new standards for parent companies of industrial loan companies and...more
12/17/2020
/ §314(b) ,
Banking Sector ,
Branch Offices ,
Brokered Deposits ,
Brokers ,
Comment Period ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Loan Companies ,
Cyber Incident Reporting ,
Cybersecurity ,
Debt Collection ,
Disclosure Requirements ,
Environmental Policies ,
Fair Credit Reporting Act (FCRA) ,
FDCPA ,
FDIC ,
Federal Bank Regulatory Agencies ,
Federal Reserve ,
Final Rules ,
Financial Reporting ,
Financial Services Industry ,
Historic Preservation ,
Information Sharing ,
Investment Adviser ,
Investment Management ,
Investors ,
MD&A Statements ,
NEPA ,
NHPA ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Paycheck Protection Program (PPP) ,
Proposed Rules ,
Public Comment ,
Qualified Mortgage Rule ,
Registered Funds ,
SBA ,
Securities and Exchange Commission (SEC) ,
Securities Litigation ,
Securities Regulation ,
Suspicious Activity Reports (SARs)
In the News. The Office of the Comptroller of the Currency (OCC) issued a long-awaited rule seeking comment on its proposed approach to determine the Community Reinvestment Act (CRA) evaluation measure benchmarks, retail...more
11/30/2020
/ Bank Secrecy Act ,
Banking Sector ,
Benchmarks ,
Charitable Organizations ,
Comment Period ,
Community Reinvestment Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Debt Buyers ,
Debt Collection ,
Derivatives ,
Disclosure Requirements ,
Document Retention Policies ,
Due Diligence ,
Fannie Mae ,
FDIC ,
FHFA ,
Final Rules ,
Financial Adviser ,
Financial Services Industry ,
Freddie Mac ,
Interim Final Rules (IFR) ,
Investment Adviser ,
Lenders ,
MD&A Statements ,
Mutual Funds ,
Nonprofits ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
OCIE ,
Private Investment Funds ,
Proposed Rules ,
Public Comment ,
Registration Statement ,
Regulation M ,
Regulation S-K ,
Regulation S-T ,
Regulation Z ,
Regulatory Requirements ,
Relief Measures ,
Reporting Requirements ,
Risk Alert ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Student Loans ,
Supervisory Guidance
In the News. The Consumer Financial Protection Bureau (CFPB) granted a no-action letter (NAL) regarding a proposed small-dollar credit product and sought comment on the CFPB’s plan to study how consumers locate, comprehend...more
11/12/2020
/ Banking Sector ,
Banks ,
Blockchain ,
Board of Directors ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Cryptocurrency ,
Debt Settlement Services ,
Disclosure ,
Diversity ,
Enforcement Actions ,
FDCPA ,
FDIC ,
Federal Bank Regulatory Agencies ,
Federal Reserve ,
Final Rules ,
Financial Regulatory Agencies ,
Financial Services Industry ,
FinCEN ,
Geographic Targeting Order ,
Interest Rates ,
Joint Statements ,
Libor ,
Loans ,
New Guidance ,
New Rules ,
No-Action Letters ,
OCC ,
Payday Loans ,
PayPal ,
Publicly-Traded Companies ,
Real Estate Transactions ,
Shareholders ,
Small Dollar Lenders ,
Student Loans ,
Telemarketing Sales Rule ,
Title Insurance