Connecticut and Kansas recently joined California, New York, Florida, Utah, Virginia, and Georgia in enacting laws requiring lenders to provide consumer-like financing disclosures for certain
Continue Reading New Commercial Financing Laws Take Effect in Connecticut, KansasShane 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 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.
CFPB Proposes Interpretive Rule for Earned Wage Access Products
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 ProductsFinCEN, Federal Banking Agencies Propose Rules to Amend Financial Institutions’ AML/CFT Program Requirements
On June 28, 2024, FinCEN issued a Proposed Rule to amend BSA regulations that prescribe the minimum requirements for AML/CFT programs for “financial institutions.” Financial institutions subject to AML/CFT program…
Continue Reading FinCEN, Federal Banking Agencies Propose Rules to Amend Financial Institutions’ AML/CFT Program Requirements‘Buy Now, Pay Later’ Rule Adds to Retailer Compliance Obligations
The Consumer Financial Protection Bureau’s interpretive rule for Buy Now, Pay Later products classifies them as “credit cards” and their providers as “card issuers” and “creditors” under the Truth in…
Continue Reading ‘Buy Now, Pay Later’ Rule Adds to Retailer Compliance ObligationsCFPB 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 Unveils Final Rule Banning ‘Excessive’ Credit Card Late Fees
On March 5, 2024, the Consumer Financial Protection Bureau (CFPB) finalized a rule intended to limit late payment fees on credit cards issued by the largest credit card issuers. The…
Continue Reading CFPB Unveils Final Rule Banning ‘Excessive’ Credit Card Late FeesCFPB Proposes Rule to Reclassify Overdraft Fees Under TILA
In a move that could reshape the landscape of consumer finance, on Jan. 17, 2024, the Consumer Financial Protection Bureau (CFPB) proposed a new rule that aims to redefine overdraft…
Continue Reading CFPB Proposes Rule to Reclassify Overdraft Fees Under TILA