On Oct. 18, 2024, fintech trade group Financial Technology Association (FTA) filed a lawsuit challenging the Consumer Financial Protection Bureau’s (CFPB) final interpretative rule on “Buy Now, Pay Later” (BNPL)
Continue Reading Lawsuit Challenges CFPB’s ‘Buy Now, Pay Later’ RuleFeatured
FTC Announces Final ‘Click-to-Cancel’ Rule for Subscription Services and Other Negative Option Offers
On Oct. 16, 2024, the Federal Trade Commission announced its final “Click-to-Cancel” Rule for subscription services and other negative option offers. The rule requires sellers to make it as easy…
Continue Reading FTC Announces Final ‘Click-to-Cancel’ Rule for Subscription Services and Other Negative Option OffersSEC Division of Examinations 2025 Priorities
The Securities and Exchange Commission’s Division of Examinations (Division) announced its 2025 examination priorities (Exam Priorities) Oct. 21, 2024. These priorities address areas of concern based on recent examinations, and…
Continue Reading SEC Division of Examinations 2025 PrioritiesFDIC Proposes New Requirements for Custodial Accounts
On Oct. 2, 2024, the Federal Deposit Insurance Corporation (FDIC) published a notice of proposed rulemaking (Proposed Rule) designed to strengthen recordkeeping requirements for custodial deposit accounts with transactional features…
Continue Reading FDIC Proposes New Requirements for Custodial AccountsUK FCA Proposes Changes to Safeguarding Regime for Payments and E-Money Firms
The UK Financial Conduct Authority (FCA) has proposed significant changes to the safeguarding requirements for UK registered payments and e-money firms (CP24/20). The FCA’s goal is to replace the current…
Continue Reading UK FCA Proposes Changes to Safeguarding Regime for Payments and E-Money FirmsCTA Countdown: Upcoming FinCEN Filing Deadlines
The Corporate Transparency Act (CTA) has been in effect since Jan. 1, 2024, requiring non-exempt U.S. entities and non-exempt foreign entities that are registered to do business in the United…
Continue Reading CTA Countdown: Upcoming FinCEN Filing DeadlinesCFTC Further Narrows Scope of Relief Under Regulation 4.7 ‘Registration Lite’
On Sept. 12, 2024, the Commodity Futures Trading Commission (CFTC) took another step toward limiting the availability and scope of relief provided by CFTC Regulation 4.7 (Reg. 4.7) under the…
Continue Reading CFTC Further Narrows Scope of Relief Under Regulation 4.7 ‘Registration Lite’New Commercial Financing Laws Take Effect in Connecticut, Kansas
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, KansasCFPB 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