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FTC Targets “Merchant of Record” for Unlawful Payment Processing, TSR, and ROSCA Violations

In a development that underscores the Federal Trade Commission’s (FTC) growing scrutiny of the “merchant of record” model, the commission announced a $5 million settlement with UK-based Paddle.com Market Limited (Paddle),...more

State Attorney General Investigations: What Consumer Financial Services Companies Need to Know

State attorneys general (AGs) have long played a significant role in consumer protection enforcement, often acting as frontline regulators alongside federal agencies. For consumer financial services companies, an AG...more

The Biden/Chopra CFPB's 2025 Guidance Compendium: A Last Gasp or Lasting Legacy?

On the eve of a change in administration, the Biden/Chopra CFPB released a "Compendium of Recent CFPB Guidance," a sweeping collection of interpretations of federal consumer financial laws under the current leadership...more

Crystal Clear: New Guide on Third-Party Risk Management for Community Banks - and Others

It is no secret that the Federal Reserve, the FDIC, and the OCC have zeroed in on banks' use of third parties for products, services, and other operations, the risks those arrangements may pose, and banks' responsibility to...more

Bank Provider of BaaS Dinged by OCC; Blueprint for Fintech Partnerships?

​​​​​​​A recent action by the Office of the Comptroller of the Currency (OCC) highlights how banks need to ensure that they have robust compliance programs for managing risks posed by their banking as a service (BaaS)...more

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