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.”
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CFPB 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
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SEC Broadens Scrutiny of Employment and Separation Agreements Under Whistleblower Rule
In 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
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Corporate Transparency Act: Compliance Deadline Approaching for FinCEN’s Beneficial Ownership Information Reporting Requirements
The 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
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NYDFS Updates Guidance on Virtual Coin-Listing/Delisting Frameworks and the Greenlist
On 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)
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CFPB Proposes Changes to Fair Credit Reporting Act to Remove Medical Debt from Credit Reports
On 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
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CFPB Issues Guidance on Credit Denials Involving Artificial Intelligence
On 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
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Maryland Office of Financial Regulation Provides Guidance on Earned Wage Access Products
On 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
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CFPB Spotlight Targets Mobile ‘Tap-To-Pay’ Technology
Big 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.
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CFPB Updates Small Business Lending Rule FAQs
On 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)
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