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, 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.

The Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring all money services businesses (MSBs) located in 30 ZIP codes across California and Texas to, among other things, report and maintain records of cash transactions exceeding $200 (up to $10,000), and to verify the identity of persons presenting such transactions
Continue Reading Effective April 14: FinCEN GTO Requires MSBs Along US Southwest Border to Report Transactions in Currency of More than $200

In October 2024, the California DFPI finalized regulations for providers of income-based advances (Earned Wage Access or EWA), clarifying registration requirements under the California Consumer Financial Protection Law (CCFPL). These

Continue Reading California DFPI Finalizes New Earned Wage Access Regulations

In its continued focus on so-called illegal “junk fees,” the CFPB issued an Advisory Opinion on the obligations of large banks and credit unions. The CFPB’s actions arise at a

Continue Reading CFPB Issues Advisory Opinion on ‘Illegal Junk Fees’ By Large Financial Firms

On June 15, 2023, Nevada Gov. Joe Lombardo signed SB 290, establishing the nation’s first state licensing regime for earned wage access (EWA) services provided to consumers in the

Continue Reading Nevada Enacts Nation’s First State Licensing Regime for Earned Wage Access Services