On Oct. 11, 2023, the FTC released a proposed rule that would, if finalized in its present form, prohibit “misleading” fees and require more prominent disclosures for so-called “junk fees.”
Continue Reading FTC Proposes Rule Targeting ‘Junk Fees’
News & Commentary on Financial Regulatory and Compliance Matters
On Oct. 11, 2023, the FTC released a proposed rule that would, if finalized in its present form, prohibit “misleading” fees and require more prominent disclosures for so-called “junk fees.”…
Continue Reading FTC Proposes Rule Targeting ‘Junk Fees’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 FirmsIn September 2023, the Securities and Exchange Commission (SEC) announced three separate enforcement orders reflecting a renewed interest in and scrutiny of provisions in employment agreements and separation agreements. These…
Continue Reading SEC Broadens Scrutiny of Employment and Separation Agreements Under Whistleblower RuleThe Corporate Transparency Act of 2019 (CTA), enacted as part of the Anti-Money Laundering Act of 2020, requires, for the first time, that certain U.S. legal entities and foreign entities…
Continue Reading Corporate Transparency Act: Compliance Deadline Approaching for FinCEN’s Beneficial Ownership Information Reporting RequirementsOn Sept. 18, 2023, the New York State Department of Financial Services (NYDFS) issued a press release announcing updates to its ongoing oversight of the digital asset space, including (1)…
Continue Reading NYDFS Updates Guidance on Virtual Coin-Listing/Delisting Frameworks and the GreenlistOn Sept. 21, 2023, the CFPB outlined new proposals aimed at medical bills and the broader credit reporting landscape, which could have far-reaching implications for creditors, consumers, and the industry…
Continue Reading CFPB Proposes Changes to Fair Credit Reporting Act to Remove Medical Debt from Credit ReportsOn Sept. 19, 2023, the CFPB issued guidance (Guidance) concerning the legal obligations creditors must observe when employing complex algorithms, marketed as artificial intelligence (AI), and other predictive decision-making technologies…
Continue Reading CFPB Issues Guidance on Credit Denials Involving Artificial IntelligenceOn Aug. 1, 2023, the Maryland Office of Financial Regulation (OFR) published new guidance on Earned Wage Access (EWA) products, intending to provide clarity on how EWA products are viewed…
Continue Reading Maryland Office of Financial Regulation Provides Guidance on Earned Wage Access ProductsBig Tech companies, fintechs, and traditional financial institutions are paying attention to the Consumer Financial Protection Bureau’s (CFPB) September 2023 issue spotlight, which focuses on tap-to-pay or contactless payment technology.
Continue Reading CFPB Spotlight Targets Mobile ‘Tap-To-Pay’ TechnologyOn Sept. 14, 2023, the CFPB issued updates to its FAQs to assist small business lenders and finance companies with complying with the final Small Business Lending Rule (the Rule)…
Continue Reading CFPB Updates Small Business Lending Rule FAQs