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CFPB Set to Limit Credit Card Late Fees

The move becomes effective on October 1, 2023, with the Supreme Court soon to decide on the agency’s rule-writing authority. On February 1, 2023, the Consumer Financial Protection Bureau (CFPB) proposed a rule (the...more

Money Transmission Modernization Act Adopted in Several States

The Act aims to modernize and streamline state regulation of money transmitters while promoting innovation and consumer protection. More than a dozen US states have enacted the Money Transmission Modernization Act (MTMA)...more

States Enact Laws Regulating Earned Wage Access Services

New laws implement regulatory standards and licensing requirements for fintechs seeking to improve employee access to wages. On June 13, 2023, Nevada enacted a law that regulates earned wage access (EWA) services provided...more

FRB Clarifies Supervision of Digital Assets and Bank-Fintech Partnerships

A new program addresses innovative banking activities such as bank-fintech partnerships and digital assets while reinforcing guardrails around stablecoin activity. On August 8, 2023, the Board of Governors of the Federal...more

SEC v. Ripple: A Tale of Two Token Transaction Types

A bifurcated decision in a highly anticipated digital assets enforcement action may not provide the clarity that market participants want or need. On July 13, 2023, Judge Analisa Torres of the US District Court for the...more

Federal Reserve Launches FedNow Real-Time Payment Service

Consumers and businesses stand to benefit from rapid access to funds at any time when routed through participating financial institutions. On July 20, 2023, the Federal Reserve announced the long-awaited launch of its...more

FRB Vice Chair for Supervision Recommends Stronger Capital Standards for Large US Banks

After a lengthy “holistic” review and a spring banking crisis, US bank capital requirements finally face overhaul. On July 10, 2023, US Federal Reserve Board (FRB) Vice Chair for Supervision Michael Barr delivered a...more

What’s Next for DAOs in the Wake of the Ooki Decision?

The viability of DAO structures draws attention after a judge declares that a decentralized autonomous organization is a “person” under the law. On June 8, 2023, the US District Court for the Northern District of...more

FRB Governor Recommends Circumspect Approach to Bank Regulatory Reform

Governor Bowman calls for transparent supervisory expectations and attention to the consequences of regulatory reform on the broader financial system. On June 25, 2023, US Federal Reserve Board (FRB) Governor Michelle W....more

Agencies Issue Guidance for Banking Organizations on Managing Risk in Third-Party Relationships

The guidance outlines principles and key considerations for banking organizations as they navigate risks associated with third parties, including fintechs. On June 6, 2023, the Federal Deposit Insurance Corporation...more

Florida Law to Restrict the Use of Certain ESG Factors by Asset Managers and Financial Institutions

The legislation mirrors anti-“industry boycott” legislation introduced or passed in other US states and provides more explicit rubrics of prohibited factors. On May 5, 2023, Florida Governor Ron DeSantis signed into law...more

Global Regulators React to Banking Sector Turbulence

The spring of 2023 saw more dislocation in the global financial sector than any time since the 2008-09 financial crisis. In the US, banking institutions with over $500 billion in total assets failed, and other banks that were...more

New Federal Exemption Changes the Registration Landscape for M&A Brokers

The narrower M&A broker exemption supersedes the 2014 M&A broker no-action letter while leaving state-level restrictions and foreign M&A broker relief unaffected. On March 29, 2023, the Securities Exchange Act of 1934...more

New York Attorney General Proposes Stringent Crypto Bill

The CRPTO Act is intended to increase transparency and consumer protections, and reduce conflicts of interest, through heightened disclosures and penalties. On May 5, 2023, New York Attorney General (NYAG) Letitia James...more

CFPB Finalizes Rule on Small Business Lending Data

The rule requires that lenders collect and report extensive applicant data to the CFPB, intended to deter discrimination and promote economic growth. On March 30, 2023, the Consumer Financial Protection Bureau (CFPB)...more

Bored Apes Scores Win in Protecting Its Trademarks

In a major Web3 trademark infringement case, NFT creators prevail over those with a bad-faith intent to profit. On April 21, 2023, Yuga Labs, the original creators of the Board Ape Yacht Club (BAYC) non-fungible token...more

SEC Tackles Digital Assets in Reopened Proposal to Reinterpret Definition of “Exchange”

Whereas the original proposal did not directly discuss digital assets, the reopening release is mainly focused on digital asset platforms. On April 14, 2023, the Securities and Exchange Commission (SEC) issued a release...more

US House Financial Services Committee Wrangles Over Stablecoins

Congress will be “starting from scratch” in attempting to establish a regulatory framework for stablecoins — an issue that many believe is the top digital asset legislative priority. On April 15, 2023, the US House...more

FDIC Vice Chairman Cautions Against New Regulation as a Response to Recent Bank Failures

In contrast with the White House’s position, the Vice Chairman denied that loosened Dodd-Frank rules contributed to the recent bank failures. On April 12, 2023, Federal Deposit Insurance Corporation (FDIC) Vice Chairman...more

White House Recommends Stricter Regulations for Large Regional Banks

President Biden is calling for tougher standards and supervision for large regional banks in the wake of recent instability in the US banking sector. On March 30, 2023, the White House issued a Fact Sheet calling on the...more

Blockchain Regulatory Certainty Act Would Protect Non-Custodial Crypto Services

The bipartisan bill would provide a federal safe harbor for non-custodial blockchain service providers from state money transmission and digital asset licensing laws. On March 23, 2023, US House of Representatives...more

Illinois Considering Crypto Licensing

A legislative initiative in Illinois would establish licensing and consumer protection requirements for digital asset businesses serving consumers in the state. On February 21, 2023, the Illinois Department of Financial...more

Wyoming Stable Token Act Enacted Into Law

By authorizing the issuance of a stable token, “Blockchain Valley” leads the way in state digital asset adoption and integration. For the last few years, Wyoming has been a leader among US states at the intersection of...more

Federal Reserve Establishes Bank Term Funding Program to Stabilize Financial System

The decisive action will mitigate emerging liquidity and solvency risks, contain pressure on the banking system, and protect depositors. On March 12, 2023, the Board of Governors of the Federal Reserve System (Federal...more

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