Since the beginning of 2025, sixteen states have proposed legislation to regulate earned wage access. These states would join Kansas, Missouri, Nevada, South Carolina, and Wisconsin, which have each enacted legislation to...more
On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued notice of a proposed interpretive rule (Rule) that walks back a prior 2020 Advisory Opinion on the manner in which Regulation Z defines “credit.” The...more
But upon closer consideration, there is an interplay between a bank partner program and the Electronic Fund Transfer Act (EFTA) as implemented by Regulation E, particularly when it comes to timeframes for disputes, liable...more
9/15/2023
/ Bank Partnership Lending Programs ,
Bank Secrecy Act ,
Board of Governors ,
Consumer Financial Protection Bureau (CFPB) ,
EFTA ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
FinTech ,
Non-Bank Lenders ,
Non-Depository Institutions ,
OCC ,
Regulation E ,
Risk Management ,
Third-Party ,
UDAAP
On February 22, 2023, the United States District Court for the Southern District of New York in Rider v. Uphold HQ Inc. held that cryptocurrencies constitute “funds” under the Electronic Fund Transfer Act (EFTA). The...more
On May 24, 2022, the Consumer Financial Protection Bureau (CFPB) announced that it is replacing the Office of Innovation with the newly-established Office of Competition and Innovation. The CFPB intends to “help spur...more