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
Continue Reading CFPB Proposes Interpretive Rule for Earned Wage Access ProductsW. 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.
CFPB Issues Final Rule Requiring Certain Nonbanks to Report Final Public Orders and Submit Annual Compliance Reports
On May 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued a Final Rule (the Rule) requiring certain nonbank “covered persons” to report certain final public orders issued by a…
Continue Reading CFPB Issues Final Rule Requiring Certain Nonbanks to Report Final Public Orders and Submit Annual Compliance ReportsCFPB Issues Advisory Opinion on ‘Illegal Junk Fees’ By Large Financial Firms
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 FirmsNevada Enacts Nation’s First State Licensing Regime for Earned Wage Access Services
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 ServicesCFPB Issues Report on Unlawful ‘Junk Fees’ Uncovered in Deposit Accounts, Multiple Loan Servicing Markets
On March 8, 2023, the Consumer Financial Protection Bureau (CFPB) released the Supervisory Highlights Junk Fees Special Edition (Report) detailing unlawful fees the agency found in deposit accounts and in…
Continue Reading CFPB Issues Report on Unlawful ‘Junk Fees’ Uncovered in Deposit Accounts, Multiple Loan Servicing MarketsCFPB Expands Anti-Discrimination by Applying UDAAP to Credit and Non-credit Products
The Consumer Financial Protection Bureau has expanded its anti-discrimination oversight and enforcement of covered persons to all consumer finance products and services, regardless of whether they involve an extension of…
Continue Reading CFPB Expands Anti-Discrimination by Applying UDAAP to Credit and Non-credit Products
Federal Reserve System Takes First Step Toward Creating Its Own Digital Currency
On Jan. 20, 2022, the Board of Governors of the Federal Reserve System (Fed) issued the Money and Payments: The U.S. Dollar in the Age of Digital Transformation paper (Paper)…
Continue Reading Federal Reserve System Takes First Step Toward Creating Its Own Digital Currency
CFPB Begins Scrutinizing Companies Using ‘Buy Now, Pay Later’ Credit
The Consumer Financial Protection Bureau (CFPB) has begun information-gathering inquiries into multiple companies that offer “buy now, pay later” (BNPL) credit to merchants and consumers, citing concerns about “accumulating debt,…
Continue Reading CFPB Begins Scrutinizing Companies Using ‘Buy Now, Pay Later’ Credit