On November 1, 2021, the President’s Working Group on Financial Markets (PWG), along with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) (collectively, the Agencies) issued a Report on Stablecoins (the Report).
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New Nevada Law Protects Limited-English Proficiency Consumers by Requiring Translation of Certain Financial Legal Documents
How to provide financial services to limited-English proficiency (“LEP”) consumers has become a pressing legal issue. Both federal and state laws provide requirements and limitations regarding translations of financial documents. Earlier this year, the Consumer Financial Protection Bureau (“CFPB”) published…
Bank Regulators Propose Interagency Guidance on Fintech Partnerships
On July 12, 2021, the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) proposed interagency guidance on how banks should manage third-party relationships,…
OCC’s Fintech Charter Survives After Reversal in the Second Circuit
After years of litigation, the Office of Comptroller of the Currency’s (“OCC”) special purpose national bank charter (“fintech charter”) survives to see another day. On June 3, 2021, the Second Circuit reversed the district court’s decision denying the OCC’s motion…
Oral Arguments Held in Challenge to OCC’s Fintech Charter
On March 9, 2021, the Second Circuit heard oral arguments in connection with the New York Department of Financial Services’ (“DFS”) challenge to block the Office of Comptroller of the Currency’s (“OCC”) special purpose national bank charter (“fintech charter”). The…
SEC 2021 National Exam Program Examination Priorities
On March 3, the Securities and Exchange Commission released its examination priorities for 2021. While most of the list echoes priorities from previous years, this year’s version includes a greater concentration on climate-related risk and environmental, social and governance matters.…
The CFPB’s “Change of Direction” After 1 Month: New Goals, More Attorneys
It was only just over a month ago that President Biden selected David Uejio, a long-time senior leader at the CFPB with a low public profile, to lead the agency temporarily as Acting Director. But already, Mr. Uejio has made…
A Detailed Look At The CFPB’s Historic Approval of Payactiv’s Earned Wage Access (EWA) Program under Regulatory Sandbox Policy
Last week, we reported that on December 30, 2020, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issued compliance assistance sandbox (“CAS”) approval to Payactiv, Inc. (“Payactiv”) regarding specific aspects of its earned wage access (“EWA”) product.
Payactiv’s Chief Legal…
States Sue to Set Aside OCC’s True Lender Rule
New York, California and six other States filed a widely expected lawsuit on January 5 seeking to invalidate the “True Lender” Rule recently issued by the Office of the Comptroller of the Currency (“OCC”). As we previously reported, the…
CFPB Grants Historic Approval to Payactiv, Approving Payactiv’s Earned Wage Access (EWA) Program under Regulatory Sandbox Policy
On December 30, 2020, the Consumer Financial Protection Bureau (“CFPB”) granted approval to Payactiv, Inc. (“Payactiv”) to offer its earned wage access (“EWA”) program under the CFPB’s Policy on the Compliance Assistance Sandbox, among the first approvals under the CFPB’s…