Aaron Kouhoupt

Aug 29, 2024 | cannabislaw.report | Aaron Kouhoupt

McGlinchey StaffordSOURCE JD SUPRAThe U.S. Drug Enforcement Agency’s proposal to reschedule cannabis from a Schedule I to a Schedule III drug under the Controlled Substances Act (CSA) has generated considerable buzz across business sectors, including for the banks and credit unions that see opportunity and challenges in transacting in the legal marijuana space. Legality varies by use and by state, while federal law limits how financial institutions can operate.

Aug 28, 2024 | jdsupra.com | Aaron Kouhoupt

The U.S. Drug Enforcement Agency’s proposal to reschedule cannabis from a Schedule I to a Schedule III drug under the Controlled Substances Act (CSA) has generated considerable buzz across business sectors, including for the banks and credit unions that see opportunity and challenges in transacting in the legal marijuana space. Legality varies by use and by state, while federal law limits how financial institutions can operate.

Aug 27, 2024 | jdsupra.com | Rachael Aspery |Aaron Kouhoupt |Robert Savoie

On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued notice of a proposed interpretive rule (Rule) that walks back a prior 2020 Advisory Opinion on the manner in which Regulation Z defines “credit.” The Rule also declares certain types of optional consumer payments to be “incident to or a condition of the extension of credit” such that the fee is a finance charge for purposes of Regulation Z.

Aug 15, 2024 | bai.org | Aaron Kouhoupt

The U.S. Drug Enforcement Agency’s proposal to reschedule cannabis from a Schedule I to a Schedule III drug under the Controlled Substances Act (CSA) has generated considerable buzz across business sectors, including for the banks and credit unions that see opportunity and challenges in transacting in the legal marijuana space. Legality varies by use and by state, while federal law limits how financial institutions can operate.

Jul 19, 2024 | jdsupra.com | Rachael Aspery |Aaron Kouhoupt

Financial institutions have utilized service providers for a multitude of purposes over many years. The use of service providers has not historically been a controversial issue, and financial institutions have always had an obligation to manage relationships in a manner that is consistent with safety and soundness standards. Given this background, what should we do differently when evaluating so-called bank partnership programs?