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Matt White guides clients through regulatory compliance challenges and represents clients in regulatory and civil investigations and litigation.

Matt has counseled fintech and payment companies on regulatory compliance matters, including those involving the Electronic Fund Transfer Act, the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the Truth in Lending Act, and their respective implementing regulations (Regulations E, V, P, and Z). Adept with the Consumer Financial Protection Bureau’s (CFPB) Prepaid Rule, Matt has provided guidance regarding prepaid cards and related compliance.

Matt has also aided clients in developing regulatory compliant products and functionalities, including an earned wage access program, reimbursement prepaid card programs, new merchant cash advance products, and tokenized payment capabilities. In connection with products on which Matt advises, he has also negotiated high-stakes technology sales agreements involving complex regulatory issues, including compliance with data privacy laws, financial regulations, and card network rules.

Beyond helping clients strategize for regulatory complexity, Matt also helps clients navigate government investigations and enforcement actions brought by the Federal Trade Commission (FTC), CFPB, and state attorneys general.

On Dec. 22, 2023, Montana Attorney General Austin Knudsen issued an opinion clarifying that certain Earned Wage Access products are not loans under either the Montana Consumer Loan Act or the Montana Deferred Deposit Loan Act.
Continue Reading Montana Attorney General Confirms Certain Earned Wage Access Products Are Not Loans

On Nov. 7, 2023, the Consumer Financial Protection Bureau (CFPB) released a proposed rule that would, if finalized in its present form, establish the CFPB’s supervisory authority over certain “larger

Continue Reading CFPB Unveils Plan to Supervise Big Tech Digital Wallet and Payment App Providers

On Nov. 1, 2023, the Consumer Financial Protection Bureau (CFPB) issued a high-level overview of the topics covered in its proposed Personal Financial Data Rights rule: Fast Facts: Personal Financial

Continue Reading CFPB Issues ‘Fast Facts’ for Proposed Personal Financial Data Rights Rule

On Oct. 26, 2023, the U.S. District Court for the Southern District of Texas issued a nationwide injunction prohibiting the Consumer Financial Protection Bureau (CFPB) from implementing or enforcing its

Continue Reading Court Issues Nationwide Stay of CFPB’s Section 1071 Small Business Lending Rule

On Oct. 19, 2023, the CFPB released a proposed rule that, if finalized in its present form, would require covered financial institutions to provide consumers and authorized third parties with

Continue Reading CFPB Issues Proposed ‘Personal Financial Data Rights’ Rule

On Oct. 3, 2023, the U.S. Supreme Court heard oral arguments in Consumer Financial Protection Bureau (CFPB) v. Community Financial Services Association of America (CFSA) (Docket No. 22-448), a case that raises the question of whether the CFPB’s funding structure, by which it receives funding directly from the Federal Reserve rather than via a congressional appropriation, violates the U.S. Constitution’s Appropriations Clause and, if so, what the appropriate remedy should be.
Continue Reading Supreme Court Hears Oral Argument on Constitutionality of CFPB’s Funding

On Oct. 7, 2023, California Governor Gavin Newsom signed SB 478 into law. When it becomes effective July 1, 2024, the law will amend the CLRA to generally ban so-called

Continue Reading California Bans Hidden Fees, Effective July 1, 2024