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Sam Boro advises fintech companies, banks, merchants, and marketplaces in the development and launch of new payment products and services. He supports clients in negotiating agreements and partnerships, understanding regulatory compliance issues, and designing smooth user interfaces.

Weekly Fintech Focus

  • The CFPB shuts down an online lender for repeated failures related to deceptive marketing claims.
  • Some major credit bureaus announce plans to incorporate BNPL installment plans in credit reports.
  • FTC Chair Lina Khan provides comments on the CFPB’s inquiry into big tech platforms’ engagement in payments and financial services.

Continue Reading Fintech Legal Report – Week of January 7, 2022

Weekly Fintech Focus

  • The CFPB sent orders to five large BNPL companies seeking information on their business practices and regulatory posture.
  • The CFPB published its Fall 2021 rulemaking agenda, giving some insight into what the next year holds for CFPB activity.
  • The CFPB renewed its call for tech workers to become whistleblowers related to potential violations of consumer financial laws.
  • The CFPB published updated FAQs related to EFTA and Regulation E.

Continue Reading Fintech Legal Report – Week of December 17, 2021

Weekly Fintech Focus

  • The CFPB and OCC are taking a keen interest in bank overdraft practices.
  • The CFPB is working to encourage coordination with states on enforcement actions and to target repeat corporate offenders.
  • CFPB and HUD once again encourage the use of Special Purpose Credit Programs to remedy historical discrimination.
  • The Kansas City Fed issued a report on Buy Now Pay Later programs.
  • The FTC and DOJ meet with G7 counterparts to discuss competition issues for digital markets.
  • The FTC spotlights a rapid increase in gift card scams.

Continue Reading Fintech Legal Report – Week of December 10, 2021

Under the leadership of its new Director, Rohit Chopra, the Consumer Financial Protection Bureau (CFPB) appears poised to take a more active supervisory and enforcement posture, including with respect to Fintech – a sector that has not historically been a focus for the agency.  Since taking office on October 12th, Director Chopra has

Weekly Fintech Focus

  • Acting Comptroller of the Currency gave a speech describing his vision for supervising crypto and fintech firms in similar ways to banks.
  • The FTC issued enforcement policy guidance related to subscriptions and negative option marketing to tighten compliance.
  • The FTC issued a final rule amending the GLBA Safeguards Rule to cover “finders” and to significantly increase certain requirements for financial institution security requirements.

Continue Reading Fintech Legal Report—Week of November 5, 2021

Weekly Fintech Focus

  • Senators seek information about the CFPB’s agenda for fintech
  • OCC’s Acting Comptroller testifies before the Senate
  • Financial regulators updated guidance on authentication and access to services
  • FTC supports Fed’s efforts to update Regulation II to improve compliance with dual debit network availability
  • OFAC takes action against a payments company for sanctions violations
  • CFPB blogs on consumer benefits and risks of Buy-Now, Pay-Later
  • FINRA issues a report addressing cloud computing adoption by member firms
  • BIS issues a bulletin encouraging entity-based regulation of Big Tech companies

Continue Reading Fintech Legal Report—Week of August 27