Payment Law Advisor Legal Commentary and Resources for the Payment Industry

Tag Archives: no-action letter

New CFPB Proposal to Overhaul Existing No-Action Letter Policy and Create a Federal Regulatory Sandbox

Posted in Regulatory and Compliance
FinTech appears to be the next industry set to benefit from the Trump administration’s ongoing deregulatory push. The Bureau of Consumer Financial Protection’s (“Bureau”) long-gestating update to the Obama era no-action letter policy was announced as one of the final acts of outgoing Acting Director Mick Mulvaney. Though no-action letter po… Read the rest

CFPB’s First No-Action Letter: Supporting Innovation AND Supervision for Fair Lending

Posted in Regulatory and Compliance
The Consumer Financial Protection Bureau (the “Bureau”) issued its first no-action letter (“NAL”) to Upstart Network, Inc. (“Upstart”), a marketplace lender that sought to clarify that its automated model for underwriting unsecured, non-revolving loans does not present a violation of the Equal Credit Opportunity Act (“ECOA”) and… Read the rest