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California DFPI Digital Asset Lending Regulatory Year in Review

February 22, 2023 By Josh Dhyani and Aldys London

A&B ABstract: In December of 2022 California released an interagency progress report (“Report”) analyzing the current regulatory status of Web3, Crypto Assets, and Blockchain. The report was prepared pursuant to Executive Order N-9-22 (the “Order”) issued by California Governor Gavin Newsome on May 4, 2022, which declared California’s intent to regulate blockchain, including crypto assets […]

Filed Under: California, Fintech, State Law Tagged With: #California, blockchain, CCFPL, crypto, DFPI, Web3

CFPB Continues Scrutiny of Algorithmic Technology

June 8, 2022 By Josh Dhyani and Consumer Finance Team

On May 26, 2022 the Consumer Financial Protection Bureau released a Consumer Financial Protection Circular stating that creditors utilizing algorithmic tools in credit making decisions must provide “statements of specific reasons to applicants against whom adverse action is taken” pursuant to ECOA and Regulation B. The CFPB previously stated that circulars are policy statements meant […]

Filed Under: Consumer Financial Protection Bureau (CFPB), Equal Credit Opportunity Act (ECOA), Fintech Tagged With: #CFPB, AI, Fair Lending, machine learning

Update Regarding the CFPB’s Buy Now, Pay Later Orders

January 7, 2022 By Consumer Finance Team

In a prior post, we reported that the language used in orders recently issued by the CFPB to leading Buy Now, Pay Later (“BNPL”) providers suggested that the CFPB intends to use the information it collects to build enforcement cases rather than monitor market developments. We also reported that if this is the case, it […]

Filed Under: Consumer Financial Protection Bureau (CFPB), Dodd-Frank Act, Fintech Tagged With: #BNPL, #CFPA, #CFPB

Did the CFPB follow PRA requirements in issuing its Big Tech orders?

November 18, 2021 By Consumer Finance Team

On October 21, the CFPB issued a series of orders to “collect information on the business practices of large technology companies operating payments systems in the United States.” The CFPB sent the orders to six companies: Amazon, Apple, Facebook, Google, PayPal, and Square. In a statement accompanying the press release announcing the orders, Director Chopra […]

Filed Under: Consumer Financial Protection Bureau (CFPB), Dodd-Frank Act, Fintech Tagged With: #BigTech, #CFPB, #PRA

New York Proposes Guidance for Regulated Virtual Currency Licensees

January 23, 2020 By Consumer Finance Team

A&B ABstract Since the New York Department of Financial Services (“NYDFS”) finalized regulations for virtual currency firms in 2015, several regulated virtual currency licensees (“Licensees”) have sought permission to issue new virtual currencies (i.e., coins) in addition to those included in their initial license applications. On December 11, 2019, NYDFS issued Proposed Guidance in response […]

Filed Under: Fintech, Licensing, State Law Tagged With: #NYDFS, #virtualcurrency

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