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No Full TIN, No Problem: FinCEN Approves of TIN Verification Through a Third Party

On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more

FinReg Currents - Week 11

On April 1, 2025, the House Financial Services Committee issued a press release regarding a number of Committee requests to various federal agencies for rescission, modification, or re-proposal of specific Biden...more

FinReg Currents - Week 5

On February 18, 2025, President Trump signed an Executive Order designed to reduce the power of federal independent agencies by bringing them under the purview of the White House. The Executive Order provides that it applies...more

FinReg Currents - Week 4

On February 7, 2025, newly confirmed Office of Management and Budget (OMB) director Russell Vought replaced Treasury Secretary Scott Bessent as acting director of the CFPB....more

FinReg Currents - Week 3

Each week of the first 100 days of the new Trump Administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more

Core Considerations for Out-of-Network BNPL Payments

Much has been written about the Buy Now, Pay Later (BNPL) industry in the recent past. Consumers enjoy the payment flexibility and interest-free features of many BNPL products and frequently use them as a substitute payment...more

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