A&B Abstract: The Alston & Bird Consumer Finance team recognizes that this is a period of great uncertainty both for the nation and our clients. We have received numerous questions and concerns regarding what federal and state regulators are doing in light of the COVID-19 pandemic and how their response may affect day-to-day business. We […]
Licensing
New York Financial Regulator Requires COVID-19 Risk Assessment, Operational Planning
Last week the New York Department of Financial Services (the “Department”) issued letters to all its licensed financial institutions. Based on these letters (available here and here), all Department licensees must assess and plan for the financial risk of COVID-19 and, separately, develop operational plans for managing their response to the virus. The Department requires written responses “as […]
New York Proposes Licensing Consumer Debt Collectors
A&B ABstract: On January 21, 2020, New York Governor Andrew Cuomo proposed a measure to license consumer debt collectors as part of his budget bill. If enacted, the measure would require any person acting as a “consumer debt collector” in New York to obtain a license from the New York Banking Superintendent. Effective October 1, […]
California Governor Moves to Strengthen State Consumer Protection Enforcement in 2020
A&B ABstract: On January 10, 2020, California Governor Gavin Newsom released his budget summary for 2020 to 2021. Fearing that the Trump administration will further roll back consumer financial protections, Gov. Newsom proposed the California Consumer Financial Protection Law, which would provide the state’s primary financial services regulator with additional authority to enforce consumer protection […]
New York Proposes Guidance for Regulated Virtual Currency Licensees
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 […]