CFPB Subjects Large International Money Transmitters to Supervision
Posted 3 days ago

The Consumer Financial Protection Bureau (CFPB) finalized its rulemaking defining…

CFPB Subjects Large International Money Transmitters to Supervision
Presentation: A Survey of Unfair, Deceptive, and Abusive Practices
Posted 11 days ago

DWT payments team member Adam Maarec recently gave a presentation entitled…

Presentation: A Survey of Unfair, Deceptive, and Abusive Practices
New Law Aims to Limit Anti-Money Laundering Compliance Burdens for Money Transmitters
Posted 25 days ago

On August 8, 2014, President Obama signed into law a bipartisan measure, The Money Remittances Improvement Act of 2014, that allows the Secretary of the Treasury to rely on state supervisory agency examinations covering compliance with federal anti-money laundering requirements for money services businesses. The law is intended to ease…

CFPB Issues Consumer Advisory on the “Wild West” of the Virtual Currency Economy
Posted 34 days ago

The Consumer Financial Protection Bureau (“CFPB”) recently issued a consumer…

CFPB Issues Consumer Advisory on the “Wild West” of the Virtual Currency Economy
New York Becomes First State to Propose Virtual Currency Regulations
Posted 40 days ago

On July 17, 2014, the New York State Department of…

New York Becomes First State to Propose Virtual Currency Regulations
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Developments and Commentary

Consumer Financial Protection Bureau logoCFPB Subjects Large International Money Transmitters to Supervision

The Consumer Financial Protection Bureau (CFPB) finalized its rulemaking defining larger participants in the international money transfer market. Companies that engage in at least one million international money transfers each year are now considered larger participants and will be subject to the CFPB’s supervisory authority effective December 1, 2014. The ...

UDAAP PresentationPresentation: A Survey of Unfair, Deceptive, and Abusive Practices

DWT payments team member Adam Maarec recently gave a presentation entitled "A Survey of Unfair, Deceptive, and Abusive Practices" at the American Bar Association's Business Law Section's Annual Meeting in Chicago. The presentation focused on the following topics around compliance and UDAAP enforcement: 1. Background 2. Identifying UDAAP: Enforcement 3. Identifying UDAAP: Bulletins 4. What's ...

New Law Aims to Limit Anti-Money Laundering Compliance Burdens for Money Transmitters

On August 8, 2014, President Obama signed into law a bipartisan measure, The Money Remittances Improvement Act of 2014, that allows the Secretary of the Treasury to rely on state supervisory agency examinations covering compliance with federal anti-money laundering requirements for money services businesses. The law is intended to ease ...

Bitcoin FlckrCFPB Issues Consumer Advisory on the “Wild West” of the Virtual Currency Economy

The Consumer Financial Protection Bureau (“CFPB”) recently issued a consumer advisory summarizing the purported risks of virtual currencies, and announced that it would begin collecting complaints from the public regarding companies that offer products and services related to virtual currency payment technologies. More than sixteen months after the Financial Crimes ...

New YorkNew York Becomes First State to Propose Virtual Currency Regulations

On July 17, 2014, the New York State Department of Financial Services (DFS) became the first state agency to release proposed regulations specifically governing the crypto-currency industry.  The proposed regulations were published in the New York State Register on July 23, 2014, initiating a 45-day public comment period under the ...

Resource Updates

A Survey of Activities Identified as Unfair, Deceptive, or Abusive by the CFPB

DWT payments team member Adam Maarec recently co-authored an article entitled "A Survey of Activities Identified as Unfair, Deceptive, or Abusive by the CFPB," published by the American Bar Association. In January 2014, the authors released a survey of activities identified as unfair, deceptive or abusive (UDAAP) by the CFPB in 2012 & 2013. ...

plaresourceFair Lending Analysis of Credit Cards

PLA today posts a link to a Philly Fed discussion paper entitled “Fair Lending Analysis of Credit Cards.”  The paper addresses, among other matters, disparate impact risks in credit scoring models and prescreen campaigns.  The paper is of interest not only for its conclusions and recommendations, but also as an ...

Requirements-and-Best-Practices-for-Truncating-Card-Account-Numbers1-300x177FACTA Class Actions

In the July 2014 issues of The Review of Banking & Financial Services, DWT payments team members Burt Braverman and Micah Ratner wrote about the truncation requirement of FACTA, which has spawned a wave of class action litigation with potentially ruinous damages for “willful” violations. The authors describe the court rulings ...

Failure of Mandated Disclosures

PLA often posts links to scholarly articles assessing or speculating about the effectiveness, from a consumer-protection standpoint, of disclosure and other regulatory regimes.  Past such posts include, for example, “Behaviorally Informed Financial Services Regulation,” “The Cost of Anchoring on Credit-Card Minimum Payments,” “Insights from Behavioral Economics for Personal Finance,” and ...

Consumer Financial Protection Bureau logoFTC Responds to CFPB, Submits Summary of Enforcement Activities

In response to a request from the CFPB, the FTC recently submitted  a summary of its 2013 enforcement activities (the “Summary”), which related the FTC’s enforcement actions and consumer education efforts with respect to Regulation Z (Truth in Lending), Regulation M (Consumer Leasing Act) and Regulation E (Electronic Fund Transfer ...