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Compliance as a Competitive Advantage

Recently, we presented on Compliance as a Competitive Advantage at Compliance University by Online Lenders Alliance. We shared a perspective we've developed over 20 years of working with financial services companies: that...more

California Bill Would Expand DFPI's Power to Police Financial Services Misconduct

A new proposal in California, Senate Bill 825 (SB 825), is intended to strengthen the enforcement authority of the state's Department of Financial Protection and Innovation (DFPI) by clarifying that it can take action against...more

New York’s Consumer Protection Overhaul: A Lawsuit Magnet for Banks, Fintechs, and Other Financial Services Providers

New York lawmakers—with full support from the attorney general—are pushing a sweeping expansion of consumer protection laws that could turn routine financial transactions into the next big class action battleground and expand...more

Crossing the Pond: What UK Fintechs Taking a Fresh Look at the U.S. Market Need to Know

For years, UK-based consumer finance and payments firms have viewed the U.S. regulatory landscape as complex, fragmented, and challenging when it comes to expansion. But 2025 may prove to be a turning point....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

McKernan's CFPB Nomination Hearing: What It Means for Consumer Financial Services Regulation

The Senate Banking Committee's hearing on Jonathan McKernan's nomination to lead the Consumer Financial Protection Bureau (CFPB) signals a potential shift in the agency's direction: McKernan, a Trump nominee, pledged to...more

Consumer Finance’s Deregulatory Shift - The Evolving Role of Compliance

With federal regulatory pressure easing, consumer financial services companies are well positioned to pursue growth with fewer potential roadblocks. ...more

Navigating Financial Services M&A: Observations from Regulatory Due Diligence

As we move into 2025, anticipation in the financial services industry continues to build for a revitalized mergers and acquisitions (M&A) market. ...more

The CFPB's 2021 Taskforce Report: A Playbook for the Future of Consumer Financial Law?

As political tides shift, so too does the regulatory outlook for consumer financial services. Among the key documents that could shape the direction of U.S. financial regulation is a January 2021 report by the CFPB Taskforce...more

CFPB Proposes Interpretive Rule Clarifying EFTA Application to Crypto and Other Emerging Payment Mechanisms

The Consumer Financial Protection Bureau (CFPB) has proposed an interpretive rule aimed at addressing what it views as ambiguities in the application of the Electronic Fund Transfer Act (EFTA) and its implementing Regulation...more

CFPB Seeks Public Input on Privacy and Data Practices in Consumer Finance

The Consumer Financial Protection Bureau (CFPB) issued a Request for Information (RFI) to gather insights on how companies offering financial products and services collect, use, and monetize consumer payment and personal...more

CFPB's Proposed Rule Targets Consumer Financial Contracts

The Consumer Financial Protection Bureau (CFPB) issued a proposed rule under Regulation AA to address the use of restrictive and coercive clauses in consumer financial contracts. This proposal seeks to prohibit terms in...more

California DFPI Seeks Feedback on Expanding Registration and Reporting to New Sectors

The California Department of Financial Protection and Innovation (DFPI) is inviting stakeholders to suggest new financial service industries that may need registration and reporting requirements under the California Consumer...more

California DFPI's New Requirements for Debt Settlement, Education Finance, and Wage Access Providers

The California Department of Financial Protection and Innovation (DFPI) has implemented new registration requirements under the California Consumer Financial Protection Law (CCFPL), effective February 2025. ...more

Navigating the CFPB's Personal Financial Data Rights Rule: What Financial Institutions Need to Know

The Consumer Financial Protection Bureau (CFPB) has finalized the much-anticipated Personal Financial Data Rights Rule, 12 CFR 1033, a sweeping regulation that will have profound implications for data providers in the...more

Navigating the CFPB’s Nonbank Enforcement Action Registry Coverage and Deadlines

It may be a familiar role for legal and compliance teams to advise on and implement compliance decisions related to registrations, but that doesn't mean the upcoming deadlines for complying with the first-of-its-kind CFPB...more

CFPB Issues FAQs: Expands Interpretive Rule for BNPL Products

On September 18, the CFPB issued a set of Frequently Asked Questions (FAQs) related to Buy Now, Pay Later (BNPL) products. These FAQs follow the CFPB's release of the 2024 BNPL Interpretive Rule (Interpretive Rule), which...more

Custody Battles: The FDIC's Latest Proposed Rule on FBO Accounts

The FDIC has issued a proposed rule that would apply to practically all bank-fintech arrangements that use custodial deposit accounts to provide customers with transactional features (also called "FBO" accounts for short)....more

CFPB to Tackle Customer Service, Chatbots

The CFPB is expected to initiate a rulemaking process that would require companies under its jurisdiction to let customers talk to a human by pressing a single button. The CFPB also has plans to issue rules or guidance...more

CFPB to Launch Registry of Nonbank Enforcement Actions

In a move that's sure to make nonbank financial institutions even more uncomfortable, the Consumer Financial Protection Bureau (CFPB) has decided to shine a brighter light on those that have been alleged to violate consumer...more

What the CFPB’s Supreme Court Victory Means for Financial Institutions

Until recently, the most popular topic of discussion in the financial services world has been the outcome of the Supreme Court case CFPB v. Community Financial Services Association of America, regarding the constitutionality...more

Lead Generation: An Excerpt from the Advertising Law Tool Kit

In the evolving world of lead generation and performance-based customer acquisition, the quest for profits can lead to big legal risks, some of them too large for advertisers that buy leads through third parties. Advertisers...more

OCC's Latest Guidance on Buy Now, Pay Later Products Signals Increasing Federal Oversight

Consumer use of "buy now, pay later" (BNPL) products and programs has proliferated over the last few years. While federal oversight has not been extensive to date, new guidance from the Office of the Comptroller of the...more

CFPB Key Regulatory Initiatives Targeted for 2024

The CFPB's latest regulatory agenda signals that the Bureau expects final rules on several key regulatory initiatives to move forward in the next several months. The agenda lists the regulatory matters that the CFPB...more

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