On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued a Proposed Interpretive Rule and Request for Comment (Proposed Rule) addressing credit products in the paycheck advance marketplace, such as those marketed as “earned wage access” or “earned wage advance” products (EWA).

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Tags: banking and finance, CFPB, Financial Regulation and Compliance, FRAC, GT Insight
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Photo of Shane Foster Shane Foster

Shane Foster is a shareholder with deep financial regulatory experience in areas such as banking, money transmission, lending, and fintech, among others. Serving in a high-level capacity as Chief Deputy Director at the Arizona Department of Insurance and Financial Institutions (DIFI), he oversaw

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Shane Foster is a shareholder with deep financial regulatory experience in areas such as banking, money transmission, lending, and fintech, among others. Serving in a high-level capacity as Chief Deputy Director at the Arizona Department of Insurance and Financial Institutions (DIFI), he oversaw the agency’s enforcement, depository, non-depository, consumer affairs, and insurance market conduct divisions.

As a former regulator, Shane has a thorough understanding of regulatory issues affecting the financial services sector and has deep experience in licensing, compliance, investigatory, and enforcement matters. From advising on chartering de novo depository institutions, merger activity, solvency and deposit insurance issues, to ensuring compliance with consumer protection and safety and soundness regulations, he provides financial institutions with insights to navigate complex issues. Additionally, his experience encompasses various consumer finance segments such as mortgage, vehicle title, and unsecured lending. Shane also led the efforts in drafting and implementing Arizona’s money transmission law (i.e., CSBS Model Money Transmission Modernization Act), which substantive provisions can be found in many states throughout the country.

Shane’s practice extends to the use of new technologies and innovation in the financial services sector. He served a prominent role in the administration of the nation’s first state regulatory sandbox, bolstering his deep understanding of the use of novel products and services in the ever evolving fintech sector (e.g., blockchain technology, digital payments, APIs, artificial intelligence, and mobile applications, among others). Shane also stays at the forefront of law and policy developments regarding digital assets. Whether dealing with transmission and custody issues or monitoring recent guidelines by federal agencies concerning crypto-related activities and stablecoins, Shane stays abreast of developments to advise clients on innovative legal strategies.

Shane has worked closely with state regulators through active involvement in the Conference of State Bank Supervisors (CSBS), National Association of Insurance Commissioners (NAIC), and the National Association of Attorneys General (NAAG), serving as a key participant in numerous multistate initiatives, including serving on the coordinating committee with the Consumer Financial Protection Bureau (CFPB) and on data privacy working groups, among others. Simultaneously, his background in government relations has given him many opportunities to interface with various federal agencies and draft comments on proposed federal policies.

Shane Foster is a sought-after speaker on a variety of topics concerning financial regulation, having spoken on numerous panels at industry and government-related events.

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Photo of W. H. Langley Perry, Jr. W. H. Langley Perry, Jr.

Langley Perry focuses his practice on federal and state regulatory compliance and state licensing for companies engaged in money transmission, consumer lending and loan servicing, commercial and residential mortgage services, debt collection, and other financial services.

Langley works on nationwide state money transmitter…

Langley Perry focuses his practice on federal and state regulatory compliance and state licensing for companies engaged in money transmission, consumer lending and loan servicing, commercial and residential mortgage services, debt collection, and other financial services.

Langley works on nationwide state money transmitter, lending, servicing, and other license acquisition projects. He provides compliance advice across a broad range of laws applicable to banks, money services businesses and non-bank consumer finance companies. He has experience handling Bank Secrecy Act/Anti-Money Laundering (BSA/AML) and Office of Foreign Assets Control (OFAC) compliance program reviews and development as well as matters involving the Financial Crimes Enforcement Network (FinCEN) and the Foreign Corrupt Practices Act (FCPA). He also advises clients on matters involving the Consumer Financial Protection Bureau (CFPB) and other federal and state regulatory authorities with oversight of consumer financial and payments products and services.

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Photo of Lisa M. Lanham ‡ Lisa M. Lanham ‡

Lisa M. Lanham focuses her practice on fintech and payments solutions within the financial services sector. Her role encompasses work with a diverse range of clients, including residential and commercial mortgage brokers, lenders, servicers, loan fulfilment providers, student, consumer, and solar loan lenders

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Lisa M. Lanham focuses her practice on fintech and payments solutions within the financial services sector. Her role encompasses work with a diverse range of clients, including residential and commercial mortgage brokers, lenders, servicers, loan fulfilment providers, student, consumer, and solar loan lenders and servicers, marketplace lenders, and entities offering retail installment contracts for consumer goods. Moreover, she advises investors engaged in secondary market activities. Lisa also extends her support to emerging fintech firms, helping them to comply with necessary state licensing requirements and develop products in these realms while keeping regulatory demands in check.

A large part of Lisa’s role involves working closely with regulators such as the New York State Department of Financial Services to facilitate her clients’ pursuit of necessary business licenses and approvals. This not only includes completing audits and examinations but also covering intricate disclosure issues and reporting changes of ownership, executive management, and qualifying individuals. In addition to these tasks, Lisa was involved in the development of the Nationwide Multistate Licensing System & Registry (NMLS) 2.0 system. She handles virtually all aspects of the NMLS, including submissions and amendments of company application forms and electronic surety bonds.

Her contributions extend to representation and regulatory counsel in areas such as structured finance, securitization, secondary market transactions, licensing matters in mergers and acquisitions transactions, regulatory agency coordination for large-scale multistate transactions, and various financial service operations. In addressing state licensing matters, Lisa has contributed to notable projects such as assisting international crypto exchanges enter into the U.S. market by setting up compliant subsidiaries.

Lisa’s work also includes the reporting of material licensing changes, providing technical reviews, analyzing proposed business models in the context of regulatory compliance issues, assisting with the development of policies and procedures for regulatory compliance concerns, negotiating findings before examination report finalization, and managing international licensing issues amidst dynamic regulatory environment.

‡ Admitted in New York and Pennsylvania. Not admitted in Florida.

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Photo of Rinaldo Martinez Rinaldo Martinez

With a client base that spans institutional investors, private equity funds, banking institutions, mortgage lenders and servicers, consumer finance companies, fintech firms, and financial services companies, Rinaldo Martinez focuses his practice on addressing the regulatory landscape of consumer credit products, both at the

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With a client base that spans institutional investors, private equity funds, banking institutions, mortgage lenders and servicers, consumer finance companies, fintech firms, and financial services companies, Rinaldo Martinez focuses his practice on addressing the regulatory landscape of consumer credit products, both at the federal state levels. His work necessitates delving into federal and state laws that substantively govern all aspects of consumer credit. Rinaldo also counsels on regulatory compliance issues related to commercial real estate.

As part of his practice, Rinaldo regularly navigates the complexities of Title X of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, including advising on statutes such as the Truth in Lending Act (TILA), the Real Estate Settlement Procedures Act (RESPA), the Home Mortgage Disclosure Act (HMDA), the Fair Debt Collection Practices Act (FDCPA), and the Fair Credit Reporting Act.

At the state level, his practice covers licensing statutes, anti-predatory lending laws, qualification statutes, usury limitations, and prepayment penalty restrictions. He has deep experience advising on regulatory compliance issues involving hybrid residential-commercial real property, such as “fix-flip” properties, particularly regarding licensing obligations for this product.

Rinaldo also assists clients with developing business models in the context of regulatory compliance issues arising under state law, with a focus on bank partnerships. He also assists clients with state examinations, including negotiating findings with regulators before examination report finalization. Additionally, Rinaldo assists with secondary market transactions, including securitizations, that necessitate diligence of state licensing obligations.

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