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Articles by Sean Ruff
Fastest Route To Market: Money Transmission Licensing Roadmaps For FinTechs
Bryan Reyhani’s articles from Taft Stettinius & Hollister are most popular: within Finance and Banking topic(s) in United States Taft Stettinius & Hollister are most popular: within Antitrust/Competition Law, Food, Drugs, Healthcare and Life Sciences topic(s) with readers working within the Aerospace & Defence industries Part 2 of 4: Digital Assets and the Next Layer of Licensing Complexity Framing the Problem: When “Money Transmission” Is Not Enough In Part 1 of our four part series, Fastest...
Fastest Route To Market: Money Transmission Licensing Roadmaps For FinTechs
Taft Stettinius & Hollister are most popular: within Antitrust/Competition Law topic(s) with readers working within the Aerospace & Defence industries Series Overview This article is Part 1 of a four-part series, Fastest Route to Market: Licensing Roadmaps for FinTechs. The series will trace the main licensing paths available to FinTechs seeking to move, hold, or manage customer funds or value in the United States.
CFPB Doubles Down on Buy Now, Pay Later Interpretive Rule in New FAQs | JD Supra
October 2, 2024 Cailin Liu, Obrea Poindexter, Sean Ruff Cooley LLP + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: On September 18, 2024, the Consumer Financial Protection Bureau (CFPB) published a compliance aid to its May 2024 interpretive rule, which classifies certain providers of buy now, pay later (BNPL) products as card issuers under Regulation Z.
CFPB Report Highlights ‘Aggressive,’ ‘Illegal’ Medical and Rental Debt Collection Practices | JD Supra
On September 5, 2024, the Consumer Financial Protection Bureau (CFPB) released its annual report on debt collection, drawing attention to a range of activities with respect to medical and rental debt collection that the CFPB describes as “aggressive” and “illegal.” The report underscores the CFPB’s continued focus on consumer debt collection practices – specifically those that relate to the collection of medical and rental debt, which the report labels as “consistent collections problems”...
FDIC’s Proposed Brokered Deposit Rule Could Adversely Impact Fintech-Bank Partnerships | JD Supra
In late July 2024, the Federal Deposit Insurance Corporation (FDIC) board of directors proposed a rule that would revise its standards on banks accepting brokered deposits. The proposed rule would expand the definition of brokered deposits, including by eliminating certain broad exceptions to the rule, and subject more bank deposits to heightened regulation as brokered deposits. If finalized, the proposed rule could bring broad swaths of fintech companies under the umbrella of deposit brokers.
CFPB Issues Interpretive Rule Designating BNPL Providers as Card Issuers Subject to Regulation Z | JD Supra
On May 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule stating that providers of “buy now, pay later” (BNPL) products that issue “digital user accounts” to access credit products to purchase goods and services are “card issuers” under Regulation Z. As a result, such BNPL providers will be subject to certain provisions of Regulation Z.
CFPB Highlights Financial, Privacy Risks of Consumer Transactions on Gaming Platforms
On April 4, 2024, the Consumer Financial Protection Bureau (CFPB) issued a report examining the growth and privacy risks of financial transactions in online video games and virtual worlds, noting that Americans spent approximately $57 billion on gaming transactions in 2023. The report looks at these assets’ growing use and scale across the gaming industry, the associated consumer risks, and the evolution of games and virtual worlds into online marketplaces.
CFPB Issues Proposal To Eliminate Fees On Instantaneously Declined Transactions
On January 24, 2024, the Consumer Financial Protection Bureau (CFPB) issued a notice of proposed rulemaking that would prohibit financial institutions from charging fees on transactions that are declined instantaneously or near-instantaneously.
OCC Issues Risk Management Guidance For BNPL Lending
On December 6, 2023, the Office of the Comptroller of the Currency (OCC) issued a bulletin that provides guidance to banks on managing risks associated with certain "buy now, pay later" (BNPL) loans.
OCC Issues Risk Management Guidance for BNPL Lending | JD Supra
On December 6, 2023, the Office of the Comptroller of the Currency (OCC) issued a bulletin that provides guidance to banks on managing risks associated with certain “buy now, pay later” (BNPL) loans.
CFPB Proposes Increased Oversight Of Digital Wallet And Payments Providers Through New Larger Participant Rule
On November 7, 2023, the Consumer Financial Protection Bureau (CFPB) issued a notice of proposed rulemaking (proposed rule) that would allow it to supervise digital wallet and payment app providers deemed "larger participants." The proposed rule would apply to nonbank payments companies that offer digital wallets or person-to-person payments through mobile and web applications, process more than five million covered payment transactions per year and are not a "small business concern," as...
CFPB Proposes Financial Data And Open Banking Rule
On October 19, 2023, the Consumer Financial Protection Bureau (CFPB) issued a notice of proposed rulemaking to implement Section 1033 of the Dodd-Frank Act. Section 1033 of Dodd-Frank requires covered persons to make information concerning a financial product or service that a consumer has obtained from such person available to the consumer, subject to rules implemented by the bureau.
CFPB Signals Desire To Expand Supervision Of Nonbank Payments Firms
During remarks at a payments-focused event on October 6, 2023, Consumer Financial Protection Bureau (CFPB) Director Rohit Chopra signaled that the bureau intends to expand its oversight of digital payments and the companies that provide these types of services. Chopra's statements provide additional insight into the CFPB's thinking about payments regulation and follow several recent bureau actions that highlight its particular interest in emerging payments activities.
Model Money Transmission Modernization Act: 12 States Take Action
Since the beginning of 2023, 12 states – Arkansas, Georgia, Hawaii, Indiana, Iowa, Minnesota, Nevada, New Hampshire, North Dakota, South Dakota, Tennessee and Texas – have passed legislation based, to varying degrees, on the Model Money Transmission Modernization Act (Model Act) developed by the Conference of State Bank Supervisors (CSBS), with input from a working group constituted of industry participants and regulators.
Latest CFPB Supervisory Highlights Identify Novel Violations Across Host Of Financial Products And Services
On July 26, 2023, the Consumer Financial Protection Bureau (CFPB) issued its Summer 2023 Supervisory Highlights describing key findings and violations identified during examinations conducted between July 2022 and March 2023. The findings cover a broad range of areas – including debt collection, deposits, fair lending, information technology, payday and small-dollar lending, remittances, auto origination and servicing, and mortgage origination and servicing.
Latest CFPB Supervisory Highlights Identify Novel Violations Across Host of Financial Products and Services | JD Supra
On July 26, 2023, the Consumer Financial Protection Bureau (CFPB) issued its Summer 2023 Supervisory Highlights describing key findings and violations identified during examinations conducted between July 2022 and March 2023. The findings cover a broad range of areas – including debt collection, deposits, fair lending, information technology, payday and small-dollar lending, remittances, auto origination and servicing, and mortgage origination and servicing.
Latest CFPB Supervisory Highlights Identify Novel Violations Across Host of Financial Products and Services
On July 26, 2023, the Consumer Financial Protection Bureau (CFPB) issued its Summer 2023 Supervisory Highlights describing key findings and violations identified during examinations conducted between July 2022 and March 2023. The findings cover a broad range of areas – including debt collection, deposits, fair lending, information technology, payday and small-dollar lending, remittances, auto origination and servicing, and mortgage origination and servicing.
Banking Regulators Release Guidance on Third Party Partnerships | JD Supra
On June 6, 2023, the Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal Reserve System and the Office of the Comptroller of the Currency (OCC) issued final joint guidance on managing risks associated with third-party relationships.
Banking Regulators Release Guidance On Third-Party Partnerships
On June 6, 2023, the Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal Reserve System and the Office of the Comptroller of the Currency (OCC) issued final joint guidance on managing risks associated with third-party relationships.
Banking Regulators Release Guidance on Third-Party Partnerships
On June 6, 2023, the Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal Reserve System and the Office of the Comptroller of the Currency (OCC) issued final joint guidance on managing risks associated with third-party relationships.
Treasury DeFi Report Offers Insight Into BSA Compliance
After a period of rapid innovation and growth in the virtual currency and digital asset space, state and federal regulators have recently issued statements, guidance and reports that articulate specific concerns and corresponding regulatory expectations with respect to digital asset activities. Case in point is the recent "Illicit Finance Risk Assessment of Decentralized Finance"[1] released by the U.S. Department of the Treasury last month.
Treasury DeFi Report Offers Insight Into BSA Compliance
By Sean Ruff, Adam Fleisher and Obrea Poindexter (May 8, 2023, 3:31 PM EDT) -- After a period of rapid innovation and growth in the virtual currency and digital asset space, state and federal regulators have recently issued statements, guidance and reports that articulate specific concerns and corresponding regulatory expectations with respect to digital asset activities.... Stay ahead of the curve In the legal profession, information is the key to success.
Treasury Department Releases Report on Money Laundering Risks, Decentralized Finance | JD Supra
The US Department of the Treasury has released an Illicit Finance Risk Assessment of Decentralized Finance, which indicates that the Treasury Department sees significant risks associated with decentralized finance (DeFi) services and the potential impact on efforts to combat money laundering and terrorist financing.
Treasury Department Releases Report on Money Laundering Risks, Decentralized Finance
The US Department of the Treasury has released an Illicit Finance Risk Assessment of Decentralized Finance, which indicates that the Treasury Department sees significant risks associated with decentralized finance (DeFi) services and the potential impact on efforts to combat money laundering and terrorist financing.
Recent Developments: Silicon Valley Bank and Signature Bank
After depositors rushed to withdraw funds from Silicon Valley Bank (SVB), on Friday, March 10, 2023, the US bank was closed by the California Department of Financial Protection and Innovation (DFPI), and the Federal Deposit Insurance Corporation (FDIC) was named receiver of the closed bank. SVB’s sudden failure going into the weekend created significant uncertainty – and prompted many questions about the ability to access accounts and funds held at the bank at the time it closed.
Common Questions Regarding Access to Funds After Failure of an FDIC-Insured Bank
Background On Friday, March 10, 2023, Silicon Valley Bank (SVB) was closed by the California Department of Financial Protection and Innovation (DFPI). The Federal Deposit Insurance Corporation (FDIC) was named Receiver and immediately created the Deposit Insurance National Bank of Santa Clara (DINB) to facilitate the resolution of SVB. Read the FDIC’s official press release announcing the closing of the bank and the DFPI’s press release. The FDIC also has established a resource page.
Arizona Embraces CSBS Model Money Transmission Law; West Virginia Incorporates Some Key Provisions - Financial Services - United States
On May 20, 2022, Arizona Gov. Doug Ducey signed Senate Bill 1580, which effectively replaces Arizona's current money transmission law1 with the Model Money Transmission Modernization Act (the Model Act) announced by the Conference of State Bank Supervisors (CSBS) last fall. Arizona's law will become effective on August 28.2 In addition to incorporating almost all of the Model Act, SB 1580 eliminates Arizona's unique identification requirements for transactions of $1,000 or more.
Fitness and Fat Loss Expert Sean Ruff Designs Flexible Online Weight Loss Plans
SAN JOSE, Calif., May 24, 2022 (SEND2PRESS NEWSWIRE) — Sean Ruff, a fitness and fat loss expert, is no newbie to fitness or nutrition. He works as a physical education teacher in the school system and has also been a coach and trainer for more than 15 years. Now, he’s flexing his muscles in the online world and plans to offer customized fitness and nutrition coaching to people who are focused on weight loss.
Fitness and Fat Loss Expert Sean Ruff Designs Flexible Online Weight Loss Plans
SAN JOSE, Calif., May 24, 2022 (SEND2PRESS NEWSWIRE) — Sean Ruff, a fitness and fat loss expert, is no newbie to fitness or nutrition. He works as a physical education teacher in the school system and has also been a coach and trainer for more than 15 years. Now, he’s flexing his muscles in the online world and plans to offer customized fitness and nutrition coaching to people who are focused on weight loss.
Fitness and Fat Loss Expert Sean Ruff Designs Flexible Online Weight Loss Plans Original
SAN JOSE, Calif., May 24, 2022 (SEND2PRESS NEWSWIRE) — Sean Ruff, a fitness and fat loss expert, is no newbie to fitness or nutrition. He works as a physical education teacher in the school system and has also been a coach and trainer for more than 15 years. Now, he’s flexing his muscles in the online world and plans to offer customized fitness and nutrition coaching to people who are focused on weight loss. PHOTO CAPTION: Sean Ruff, featured health and fitness expert.
CFPB Issues Bulletin To Restrain Collection And Credit Reporting Of Prohibited Medical Debt
United States: CFPB Issues Bulletin To Restrain Collection And Credit Reporting Of Prohibited Medical Debt 03 February 2022 by Michael Coburn , Obrea Poindexter and Sean Ruff Cooley LLP Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com.
CFPB Issues Bulletin to Restrain Collection and Credit Reporting of Prohibited Medical Debt | JD Supra
The Consumer Financial Protection Bureau (CFPB) has released a compliance bulletin and policy guidance reminding debt collectors that attempting to collect on or furnishing information to consumer reporting agencies regarding medical debt that is prohibited under the recently passed No Surprises Act may violate the Fair Debt Collection Practices Act (FDCPA) and Fair Credit Reporting Act (FCRA).
Federal Reserve Seeks Comments On A US Central Bank Digital Currency
United States: Federal Reserve Seeks Comments On A US Central Bank Digital Currency 02 February 2022 by Adam Fleisher , Jonathan A. Gordon , Obrea Poindexter and Sean Ruff Cooley LLP Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com.
Fintech Focus: CFPB Updates FAQs, Scrutinizes Buy Now, Pay Later Companies And Fintech Lending
United States: Fintech Focus: CFPB Updates FAQs, Scrutinizes Buy Now, Pay Later Companies And Fintech Lending 30 December 2021 by Adam Fleisher , Elyse Moyer , Obrea Poindexter and Sean Ruff Cooley LLP Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com. The Consumer Financial Protection Bureau (CFPB) has remained busy as we head into the final week of 2021.
CFPB Requests Information On Payment System Plans And Practices Of Large Technology Companies - Finance and Banking - United States
United States: CFPB Requests Information On Payment System Plans And Practices Of Large Technology Companies 11 November 2021 by Jonathan A. Gordon , Jonathan Kim , Sean Ruff and Obrea Poindexter Cooley LLP Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com.
Alert: District Judge Sides With CFPB, Upholds Payday Rule’s Payment Provisions | JD Supra
On August 31, 2021, a federal district court judge in Texas granted summary judgment to the Consumer Financial Protection Bureau in a lawsuit brought by two industry trade associations, ultimately upholding the “payment provisions” of the CFPB’s Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule (CFPB Payday Rule) first issued in November 2017.
Biden Signs Law Overturning True Lender Rule - Finance and Banking - United States
United States: Biden Signs Law Overturning True Lender Rule 12 July 2021 by Elyse Moyer (New York) , Obrea Poindexter (New York) and Sean Ruff (New York) Cooley LLP Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com. On June 30, 2021, President Joe Biden signed a joint resolution to revoke the Office of the Comptroller of the Currency's (OCC) "true lender" rule (the "Rule").
Alert: Biden Signs Law Overturning True Lender Rule | JD Supra
On June 30, 2021, President Joe Biden signed a joint resolution to revoke the Office of the Comptroller of the Currency’s (OCC) “true lender” rule (the “Rule”). Passed in October 2020, the Rule clarified that a national bank was the true lender of a loan if it was the named lender on the loan agreement or funded the loan. Under the Trump administration, the OCC said the Rule would provide regulatory clarity for banks, borrowers and other stakeholders to identify the lender in a transaction.
Biden Signs Law Overturning True Lender Rule
On June 30, 2021, President Joe Biden signed a joint resolution to revoke the Office of the Comptroller of the Currency’s (OCC) “true lender” rule (the “Rule”). Passed in October 2020, the Rule clarified that a national bank was the true lender of a loan if it was the named lender on the loan agreement or funded the loan. Under the Trump administration, the OCC said the Rule would provide regulatory clarity for banks, borrowers and other stakeholders to identify the lender in a transaction.
California Finalizes Rulemaking For Agent-of-a-Payee Exemption In Money Transmission Licensing
To print this article, all you need is to be registered or login on Mondaq.com. The California Department of Financial Protection and Innovation (DFPI) has finally adopted final rules relating to the scope of the agent-of-a-payee exemption under the California Money Transmission Act (MTA), Cal. Fin. Code § 2000 et seq.
Alert: California Finalizes Rulemaking for Agent-of-a-Payee Exemption in Money Transmission Licensing | JD Supra
The California Department of Financial Protection and Innovation (DFPI) has finally adopted final rules relating to the scope of the agent-of-a-payee exemption under the California Money Transmission Act (MTA), Cal. Fin. Code § 2000 et seq. The scope of potentially regulated activity under the MTA is broad because the MTA, like most other money transmission laws, requires a license to engage in “[r]eceiving money for transmission” unless otherwise exempt, Cal. Fin. Code §§ 2010(q)(3), 2030(a).
Who Is An Agent Of A Payee In California? With Rulemaking Pending, Possible Scope Suggested By Opinion Letters
United States: Who Is An Agent Of A Payee In California? With Rulemaking Pending, Possible Scope Suggested By Opinion Letters 02 April 2021 by Adam Fleisher , Obrea Poindexter and Sean Ruff Cooley LLP Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com.
Alert: Who is an Agent of a Payee in California? With Rulemaking Pending, Possible Scope Suggested by Opinion Letters | JD Supra
Any company that intermediates payments for other parties ─ such as a marketplace platform, a billing service, a payment facilitator or a B2B platform provider ─ must take into consideration the applicability of money transmission licensing laws. Almost all US states regulate money transmission under state-specific laws that, due to broad statutory definitions of regulated activity, can cover any entity that receives money from a payor and disburses payments to a payee.
CFPB Clarifies That Prohibition Against Sex Discrimination Includes Sexual Orientation And Gender Identity - Finance and Banking - United States
United States: CFPB Clarifies That Prohibition Against Sex Discrimination Includes Sexual Orientation And Gender Identity 17 March 2021 by Adam Fleisher , Obrea Poindexter , Ross T. Handler and Sean Ruff Cooley LLP Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com. The US Consumer Financial Protection Bureau continues to focus on fair lending and is poised to increase enforcement actions.
Are You A Money Transmitter In Florida?
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Are You A Money Transmitter In Florida? | JD Supra
The Florida Office of Financial Regulation (“OFR”) has rejected a petition for a declaratory statement seeking confirmation that payment processing activity involving the receipt of funds and transmission of such funds does not require a Florida money transmission license.
FinCEN Seeks To Expand Scope Of Information Collection And Recordkeeping Requirements For Money Transmitters And Other Financial Institutions
To print this article, all you need is to be registered or login on Mondaq.com. A new proposed rulemaking (the “NPRM”) would lower the current $3,000 threshold for the applicability of the Bank Secrecy Act (“BSA”) Recordkeeping Rule and Travel Rule to $250 for covered funds transfers that begin or end outside the United States.
FinCEN Seeks To Expand Scope Of Information Collection And Recordkeeping Requirements For Money Transmitters And Other Financial Institutions | JD Supra
A new proposed rulemaking (the “NPRM”) would lower the current $3,000 threshold for the applicability of the Bank Secrecy Act (“BSA”) Recordkeeping Rule and Travel Rule to $250 for covered funds transfers that begin or end outside the United States. This proposed change would—among other things—require nonbank financial institutions, such as money transmitters, to obtain information, including Social Security number, from all consumers that initiate covered transfers in an amount of $250 or more.
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