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CFPB Takes Aim at Major Online Payments Applications for Digital Payments; Spares Crypto Companies

On November 7, 2023, the Consumer Financial Protection Bureau ("CFPB") proposed a new rule, to be codified at 12 C.F.R. ยง 1090.109, that would bring general-use digital payment processors who process more than five million...more

Operational resilience in the UK, EU and US: A comparison

With a new operational resilience framework in force in the UK and similar reforms proposed in the EU and the US, we examine how the regimes compare and their practical impact on financial services firms....more

Virtual "Currencies": Not actual currencies

As with any new phenomenon, the rise of digital assets has created a new lexicon. "Blockchain," "tokens," and "coins" are now household vocabulary. Central to the discussion are a set of assets generally classified as...more

Fintech solutions for the financial services sector

Challenges and opportunities in the US, UK and Europe - "Many Fintechs that previously avoided bank-like regulation in the US are now actively seeking that status." The digital revolution was well underway long before most...more

Unstable: the PWG's Report on Stablecoins

On November 1, 2021, the President's Working Group on Financial Markets (the "PWG"), the Federal Deposit Insurance Corporation (the "FDIC") and the Office of the Comptroller of the Currency (the "OCC") issued a Report on...more

Stabilized: OCC settles debate about regulatory characterization of bank-issued stablecoins

On January 4, 2021, the Chief Counsel of the Office of the Comptroller of the Currency ("OCC") issued an interpretive letter ("IL 1174") on the permissibility of national banks to use independent node verification networks...more

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