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On January 22, 2025, the New York State Department of Financial Services (NYDFS) announced proposed regulations that would limit fees associated with overdrafts, nonsufficient funds (NSF) transactions and returned deposit...more
Insufficient funds transactions occur when consumers issue a payment order (a check, some other written order or an electronic debit) against funds in their bank account, and the account lacks sufficient funds to cover the...more
On January 23, 2025 the New York Department of Financial Services (NYDFS) announced proposed regulations to curb overdraft fees and insufficient funds fees charged by banks in New York. The proposed rules aim to protect...more
This session will provide a survey of key issues and trends impacting the fintech and digital assets community as well as the future opportunities and challenges presented for these financial products and services. It will...more
Over the past year, there have been numerous efforts by federal regulators - in particular the Consumer Financial Protection Bureau - to rein in "junk fees." The CFPB defines a "junk fee" to be an unnecessary and unavoidable...more
Like most industries today, Consumer Finance Services businesses continue to be significantly impacted by COVID-19. To help you keep abreast of relevant activities, below find a breakdown of some of the biggest legislative...more
Like most industries today, Consumer Finance Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Pepper has developed a dedicated COVID-19 Resource Center to guide clients...more
As spring turns to summer, climate change is on our minds. A new day, a new story about how financial institutions are addressing climate-related risks. In the past few months, six major banks—Bank of America, JPMorgan...more
In this Issue. The U.S. Securities and Exchange Commission (SEC) was very active this week, having (i) issued no-action relief allowing registered funds to engage in self-custody of interests in loans that are originated,...more
CFPB issued an advisory opinion on Earned Wage Access (EWA) on Monday afternoon. We’ve written about earned wage access products before as well as state legislative initiatives to regulate them. The new federal guidance...more
The New York Department of Financial Services ("NYDFS") and the French Autorité de Contrôle Prudentiel et de Résolution ("ACPR") signed a Memorandum of Understanding ("MOU") to position New York and France as innovation hubs...more
The New York Department of Financial Services has sent a letter directed to businesses that the DFS “understands…may be involved in online lending in the State of New York” and that asks recipients to complete a “New York...more
CFPB Issues Final Rule Temporarily Raising Reporting Threshold for Home Equity Loans Under Home Mortgage Act Rules - On August 24, 2017, the Consumer Financial Protection Bureau (the "CFPB") issued a new rule that amends...more
Sanctions: Will the Trump Administration Stay the Course? President Trump made many statements during the campaign regarding actions he plans to take to reverse Obama administration sanctions policies. These included...more
The New York State Department of Financial Services (NYDFS) has come out strongly against an Office of the Comptroller of the Currency (OCC) proposal to grant national bank charters to financial technology (fintech)...more
In December 2016, Thomas Curry, the Comptroller of the Currency, stated that cybersecurity was the single greatest systemic threat to our financial system. He was not being hyperbolic. Cybersecurity should be on...more
The announcement by the Office of Comptroller of Currency that it will allow financial technology (fintech) companies to apply for national bank charters as way of fostering “responsible innovation” has already drawn fire...more
Student lending continues to remain in the crosshairs of federal and state consumer finance regulators during the summer months, with over five enforcement actions and investigations in recent weeks. As covered in both...more