In a significant ruling, the U.S. Court of Appeals for the Ninth Circuit affirmed the dismissal of a consumer’s state law claims against a federal credit union on federal preemption grounds. The putative class action...more
8/6/2025
/ Appeals ,
Banks ,
California ,
Class Action ,
Federal Credit Unions ,
Federal v State Law Application ,
Fees ,
Financial Institutions ,
Financial Services Industry ,
Preemption ,
Putative Class Actions ,
Returned Check Fees ,
State Law Claims ,
Statutory Violations ,
Unfair Competition ,
Unfair Competition Law (UCL) ,
Unfair or Deceptive Trade Practices
On Jan. 14, Patriot Bank, based in Stamford, Connecticut, entered into an agreement with the Office of the Comptroller of the Currency to address and rectify several alleged unsafe or unsound practices and violations of law....more
7/11/2025
/ Anti-Money Laundering ,
Banks ,
BSA/AML ,
Enforcement Actions ,
Financial Institutions ,
Money Laundering ,
OCC ,
Payment Systems ,
Regulatory Requirements ,
Regulatory Violations ,
Risk Management ,
Unfair or Deceptive Trade Practices
In this special crossover edition of Payments Pros and The Consumer Finance Podcast, Carlin McCrory and Jason Cover are joined by their colleague Caleb Rosenberg to explore the evolving landscape of small business financing....more
7/10/2025
/ Banks ,
Consumer Financial Products ,
Disclosure Requirements ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
FinTech ,
Lenders ,
New Legislation ,
Regulatory Reform ,
Small Business ,
Small Business Loans ,
Startups ,
State Legislatures
In this special crossover edition of the Payments Pros and Consumer Finance podcasts, Carlin McCrory and Jason Cover are joined by their colleague Caleb Rosenberg to explore the evolving landscape of small business financing....more
7/9/2025
/ Banks ,
Disclosure Requirements ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
Financing ,
FinTech ,
Lenders ,
New Legislation ,
Regulatory Reform ,
Small Business ,
Small Business Loans ,
State Legislatures
On June 16, the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve Board, and the Office of the Comptroller of the Currency (OCC) issued a joint request for public comment on potential ways to address payments...more
6/25/2025
/ Banks ,
Consumer Financial Products ,
FDIC ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
Financial Crimes ,
Financial Services Industry ,
Fraud ,
OCC ,
Payment Systems ,
Regulatory Oversight ,
Regulatory Requirements ,
Risk Management ,
Suspicious Activity Reports (SARs)
In this episode of Payments Pros, Carlin McCrory welcomes Melissa Sneed from the Georgia Department of Banking and Finance and James Stevens, co-leader of Troutman Pepper Locke’s Financial Services Industry Group, to explore...more
In this episode of Payments Pros, host Carlin McCrory discusses a recent consent order between Patriot Bank and the Office of the Comptroller of the Currency (OCC) following a $27 million loss. The order addresses unsafe...more
4/2/2025
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
BSA/AML ,
Consent Order ,
Customer Identification Program (CIP) ,
Enforcement Actions ,
FinTech ,
OCC ,
Risk Assessment ,
Risk Management ,
Suspicious Activity Reports (SARs)
On March 17, the Office of the Comptroller of the Currency (OCC) announced that it has granted conditional approval for SmartBiz Loans to transform the business model of CenTrust Bank, N.A., located in Northbrook, Illinois....more
This week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued its final rule on personal financial data rights, purportedly aimed at enhancing consumer control over their financial data and promoting competition...more
10/24/2024
/ Banks ,
Consumer Data Requests ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Data Management ,
Dodd-Frank ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Open Banking
On October 11, the Office of Administrative Law (OAL) approved the California Department of Financial Protection and Innovation’s (DFPI) proposed regulations on direct-to-consumer (i.e., non-employer offered) earned wage...more
10/24/2024
/ Banks ,
California ,
Consumer Financial Products ,
Department of Financial Protection and Innovation (DFPI) ,
Earned Wage Access ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Loans ,
New Regulations ,
Office of Administrative Law Judges (OALJ) ,
Wage and Hour
In the latest episode of Payments Pros, hosts Carlin McCrory and Keith Barnett are joined by James Stevens to discuss recent enforcement actions in the banking as a service (BaaS) space. They delve into regulatory trends,...more
This is the first of three articles focused on a key question: as bank-fintech partnerships continue to play a vital role in driving financial services, how does the industry make this system safer and better?...more
Tuesday, the League of Southeastern Credit Unions (LSCU) and the Virginia Credit Union League (VCUL) announced plans to merge, marking the first state league consolidation since 2022. According to the leagues’ combined...more
Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more
7/29/2024
/ AML/CFT ,
Anti-Money Laundering ,
Banks ,
Consumer Financial Products ,
Customer Due Diligence (CDD) ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Joint Statements ,
OCC ,
Risk Management ,
Suspicious Activity Reports (SARs) ,
Third-Party Relationships
On April 19, Kansas Governor Laura Kelly signed House Bill (HB) 2560 to regulate earned wage access (EWA) products and services. HB 2560 enacts the Earned Wage Access Services Act that requires EWA providers to be licensed by...more
4/26/2024
/ Banks ,
Consumer Financial Products ,
Disclosure Requirements ,
Earned Wage Access ,
Electronic Fund Transfer Act ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
New Legislation ,
Payday Loans ,
Popular ,
Wage and Hour
In a recent speech at the Financial Data Exchange Global Summit, Rohit Chopra, Director of the Consumer Financial Protection Bureau (CFPB), discussed the current state of open banking in the United States and emphasized the...more
3/19/2024
/ Anti-Competitive ,
Banks ,
CFPB Director ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Open Banking ,
Proposed Rules ,
Standard Setting Organizations
On February 20, the Wisconsin Senate passed House Bill (HB) 574 to regulate earned wage access (EWA) products and services. HB 574 creates a new chapter to the Wisconsin Statutes that requires EWA providers to be licensed by...more
On January 12, Fiserv announced that it filed an application with the state of Georgia for a merchant acquirer limited purpose bank (MALPB) charter. This application is a seismic development and positive sign for those in the...more
On October 16, the Federal Reserve Board (Fed) published a notice of an Open Board Meeting to take place on October 25. The only matter under consideration at that meeting will be the Fed’s proposed revisions to the debit...more
10/20/2023
/ Administrative Procedure Act ,
Banks ,
Certiorari ,
Corner Post Inc v Board of Governors of the Federal Reserve System ,
Debit Cards ,
Dodd-Frank ,
Durbin Amendment Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Interchange Fees ,
Public Comment ,
Statute of Limitations
On July 27, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, the agencies) issued a joint notice of proposed...more
The Federal Reserve issued a press release announcing its plans for a July debut of FedNow, its service “to facilitate nationwide reach of instant payment services by financial institutions.” As previously discussed here, the...more
On February 28, the Financial Crimes Enforcement Network of the U.S. Department of Treasury (FinCEN) issued an alert warning financial institutions to be vigilant in identifying and reporting check fraud schemes targeting the...more
On February 23, The Board of Governors of the Federal Reserve System (the Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the Agencies) issued a...more
In a letter dated February 10, the American Bankers Association (ABA), Consumer Bankers Association (CBA), Credit Union National Association (CUNA), National Association of Federally‐Insured Credit Unions (NAFCU), and The...more
On January 27, the Federal Reserve Board (Fed) announced that it denied the application of Custodia Bank, a Wyoming special purpose depository institution (SPDI), for member status on the basis that its novel business model...more