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 RegulationsGT Alert
Reviewing 2024 CFTC AI Initiatives and Looking Ahead
The Commodity Futures Trading Commission (CFTC) undertook a series of initiatives in 2024 to address CFTC registrants’ and other industry participants’ use and application of AI technologies. While these actions…
Continue Reading Reviewing 2024 CFTC AI Initiatives and Looking AheadCTA Update: Nationwide Preliminary Injunction Against CTA Reinstated
On Dec. 26, 2024, the nationwide preliminary injunction that a Texas district court issued in Texas Top Cop Shop, Inc. v. Garland against enforcement of the Corporate Transparency Act (CTA)…
Continue Reading CTA Update: Nationwide Preliminary Injunction Against CTA ReinstatedCFPB’s Final Rule Enhancing Oversight of Large Digital Payment App Providers Goes into Effect Jan. 9 – Are You Ready?
On Nov. 21, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule (Rule), pursuant to 12 U.S.C. § 5514(a)(1)(B), to establish supervisory authority over nonbank entities identified as…
Continue Reading CFPB’s Final Rule Enhancing Oversight of Large Digital Payment App Providers Goes into Effect Jan. 9 – Are You Ready?Texas Court Blocks CTA Nationwide 4 Weeks Before Key Reporting Deadline
A Texas district court has issued a nationwide preliminary injunction four weeks before a key Jan. 1, 2025, reporting deadline for the Corporate Transparency Act (CTA) that, while in effect…
Continue Reading Texas Court Blocks CTA Nationwide 4 Weeks Before Key Reporting DeadlineFinCEN Adopts New Anti-Money Laundering Program, Recordkeeping and Reporting Requirements for Certain Investment Advisers
On Sep. 4, 2024, FinCEN published a final rule (Final Rule) adding certain RIAs and ERAs (collectively, Covered Advisers) to the definition of “financial institution” under the regulations…
Continue Reading FinCEN Adopts New Anti-Money Laundering Program, Recordkeeping and Reporting Requirements for Certain Investment AdvisersFTC Takes a Jab at AI-Enabled Sitejabber for Deceptive Consumer Reviews
On Nov. 6, 2024, the Federal Trade Commission (FTC) released an administrative complaint and accepted a proposed consent order resolving claims against GGL Projects, Inc., an AI-enabled customer review platform…
Continue Reading FTC Takes a Jab at AI-Enabled Sitejabber for Deceptive Consumer ReviewsFTC 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 OffersFDIC 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 Firms