Rachael Aspery

Sep 12, 2024 | jdsupra.com | Rachael Aspery |Robert Savoie

September 12, 2024 To embed, copy and paste the code into your website or blog: McGlinchey attorneys Robert Savoie and Rachael Aspery are joined by Phil Goldfeder, the CEO of the American Fintech Council, in this installment of the Deep Dive into Bank Partnerships.

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.

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?

Jul 10, 2024 | businesslawtoday.org | Barbara Sicalides |Rachael Aspery |Mimi Diallo |Nicholas Corwin

CURRENT MONTH (June 2024) Table of Contents hide Algorithmic Prices and Industry Data Reporting under the Antitrust Microscope By Barbara Sicalides and Mimi Diallo, Troutman, Pepper, Hamilton, Sanders, LLP Federal and state antitrust enforcement agencies, as well as private plaintiffs, are actively investigating and challenging companies within the same industry using common pricing algorithms, along with the software vendors or the data analytics firms that provide pricing recommendations or...

Jul 2, 2024 | jdsupra.com | Rachael Aspery |Amy Greenwood-Field

American Bar Association’s Business Law Today June Month-In-Brief: Business & Regulated Industries. On May 30, 2024, the New York Department of Financial Services (DFS) published a press release and issued guidance to Virtual Currency Entities (VCEs) concerning the DFS’s expectations for the resolution of customer service requests and complaints (Guidance), which expands upon the current requirements found in 23 NYCCR 200.20.