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CFPB Highlights Emerging Risks in the Convergence of Payments and Commerce

On August 4, 2022, the Consumer Financial Protection Bureau (CFPB) released a report on the emerging risks consumers face in the growing presence of new products that blur the line between payments and commerce, namely: buy now, pay later (BNPL) offerings; embedded commerce; and integrated “super apps.” Specifically:…

Continue Reading Fintech Legal Report—Week of August 19, 2022

Weekly Fintech Focus

  • Democratic senators urge CFPB to focus on bank liability for fraud occurring on P2P payment platforms.
  • CFPB and OCC issue $225M fine to a bank for failures related to unemployment benefits payments.
  • UK financial regulators open consultation on oversight of financial institutions’ third-party service providers.

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Continue Reading Fintech Legal Report—Week of July 22, 2022

Weekly Fintech Focus

  • The CFPB terminates a no-action letter with an AI credit underwriter.
  • A CFPB circular confirms that AI underwriting models are subject to anti-discrimination laws including adverse action notices.
  • BNPL companies and credit bureaus face urging by the CFPB to properly report consumer information.
  • The CFPB launches an initiative to improve customer service at big banks.

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Continue Reading Fintech Legal Report—Week of June 17, 2022

Weekly Fintech Focus

  • FinCEN and OFAC issue advisories on handling ransomware attacks, putting victims and those who help victims pay cybercriminals on notice that ransomware payments are risky and could result in violations of U.S. financial and sanctions laws.
  • California signs into law its new consumer protection law, creating an expanded agency and giving it new enforcement and licensing powers.

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Continue Reading Fintech Week in Review: Week of October 2, 2020

Regulatory

Fed Board Delays New Same Day ACH Processing Window Until March 2021

The effective date of the new same-day Automated Clearing House (“ACH”) processing window (which would expand the end-of-day deadline to originate same-day transactions by two hours to 4:45 p.m. ET (1:45 p.m. PT)) has been deferred by six months to March 19, 2021.  The Federal Reserve Board of Governors (the “Fed Board”) has informed the national administrator of the ACH network (the “NACHA”) that the Fed Board currently cannot commit to change the Federal Reserve services necessary to enable the new window by June 30, 2019 (the deadline that was agreed upon per Supplement #1-2018 to the NACHA Operating Rules provided for in the rule).
Continue Reading FinTech Regulatory Week in Review: Week of March 11 – 15