Searching Content by Sean Ruff from Morrison & Foerster LLP ordered by Published Date Descending.
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Assembly Bill 539 And The Future Of Consumer Loans In California
The California legislature is poised to cap rates on larger consumer installment loans.
United States
11 Jul 2019
Nevada Resident Sentenced For Fraud And Unlicensed Money Transmission In Case Involving Bitcoin
On May 28, 2019, a Nevada resident, Morgan Rockcoons, was sentenced in the U.S. District Court for the Southern District of California to 21 months in prison for wire fraud and unlicensed money
United States
18 Jun 2019
FinCEN Issues Convertible Virtual Currency Guidance And Advisory
On May 9, 2019, the Financial Crimes Enforcement Network ("FinCEN") issued a guidance, Application of FinCEN's Regulations to Certain Business Models Involving Convertible Virtual Currencies...
United States
5 Jun 2019
Take Two: Are You A Money Transmitter In Vermont?
Last year, we noted that the Banking Department of the Vermont Department of Financial Regulation had taken the position that its money transmission law "does not exempt a payment processor
United States
31 May 2019
California Invites Comments On Agent Of A Payee Exemption—Rulemaking To Follow
The California DBO has issued an Invitation for Comments relating to the scope of the "agent of a payee" exemption under the Money Transmission Act, Cal. Fin. Code §2000 et seq. (the "Act").
United States
18 Feb 2019
Are You A Money Transmitter In Michigan? In California?
The payments and money transmission regulatory landscape continues to evolve. A key new development is that Michigan has affirmed by legislation that "agent of a payee" ...
United States
9 Jan 2019
The Bureau Of Consumer Financial Protection Proposes Revised No-Action Letter Policy And New Product Sandbox
The alert discusses the Proposed Policy's intention to fix several shortcomings of the 2016 Policy and encourage companies to test new financial products and services.
United States
27 Dec 2018
Are You A Money Transmitter In California?
As we have noted on multiple occasions (see here, here and here), one of the most important questions in the non-bank payments revolution — at least from a regulatory perspective ...
United States
24 Jul 2018
Are You A Money Transmitter In Vermont?
The Banking Department of the Vermont Department of Financial Regulation recently entered into a consent order with a money transmission licensing applicant.
United States
26 Jun 2018
South Carolina's Money Transmission Law Comes Into Effect
Yesterday, the Office of the South Carolina Attorney General ("AG") issued a press release announcing that it has created a Money Services Division ("Division") within the AG's office...
United States
17 May 2018
Are You A Money Transmitter In Connecticut? In Hawaii?
Money transmission licensing laws were crafted to address what today would be called "traditional" money transmitters—i.e. ...
United States
23 Nov 2017
OCC Acting Comptroller Woos Fintech Companies With Remarks On Online Lending
On September 25, 2017, Acting Comptroller of the Currency Keith Noreika discussed online lending and innovation in his keynote remarks prepared for delivery to the Online Lending Policy Summit in Washington, D.C....
United States
4 Oct 2017
OCC Releases Semiannual Risk Perspective: Fintech
On July 7, 2017, the Office of the Comptroller of the Currency ("OCC") released its Semiannual Risk Perspective report (the "Report")...
United States
20 Jul 2017
FDIC Action Is A Reminder That Bank Partnerships Are Not A Panacea For Non-Banks
The FDIC released orders for restitution and to pay civil money penalties (Orders), but did not release the consent agreements executed by the Bank, FSI or MCS with the stipulated facts and findings.
United States
25 May 2017
CFPB Files Suit Challenging Tribal-Affiliated Lenders Using its UDAAP Authority
The CFPB is seeking injunctive relief and damages against the online lenders.
United States
9 May 2017
OCC Announces Special Purpose National Bank Charter For FinTech Companies
On December 2, 2016, Comptroller of the Currency Thomas Curry confirmed that the agency will begin considering applications from FinTech companies to become special purpose national banks...
United States
9 Dec 2016
OCC Lays Out Responsible Innovation Framework
On October 26, 2016, the Office of the Comptroller of the Currency ("OCC") issued its Recommendations and Decisions for Implementing a Responsible Innovation Framework ("Framework").
United States
8 Nov 2016
Senators Ask Banking Agencies To Outline FinTech Oversight
On July 21, 2016, Senators Sherrod Brown and Jeff Merkley sent a letter to the heads of five federal agencies requesting that they outline the steps they are taking...
United States
1 Aug 2016
OCC Announces Preliminary Framework On FinTech And Responsible Innovation
On March 31, 2016, the Office of the Comptroller of the Currency ("OCC") released a white paper on financial technology innovation ("White Paper"), which lays out a preliminary framework for "responsible innovation."
United States
13 Apr 2016
CFPB Calls For Complaints About Marketplace Lenders
On March 7, 2016, the CFPB made its first official moves on "marketplace lending," which also may be known as "peer-to-peer" lending.
United States
15 Mar 2016
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