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Sep 12, 2024 | 
jdsupra.com | Rachael Aspery |Robert Savoie
September 12, 2024
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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.
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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.
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Jul 1, 2024 | 
jdsupra.com | Rachael Aspery |Robert Savoie
On June 18, 2024, in NAIB, et al v.
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Jun 17, 2024 | 
businesslawtoday.org | Rachael Aspery |Robert Savoie
Consumers often are able to effect transactions by providing payment authorization ahead of time. How often a consumer may authorize a prescheduled transaction differs slightly under Regulation E and the National Automated Clearing House Association (“NACHA”) Operating Rules and Guidelines (“NACHA Rules”). Very generally, Regulation E governs preauthorized electronic fund transfers (“EFTs”), while the NACHA Rules govern standing authorizations.
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Jun 6, 2024 | 
jdsupra.com | Aaron Kouhoupt |Robert Savoie
Bank partnership programs have grown exponentially in recent years as a collaborative framework for banks and non-depository institutions to offer innovative and unique products to their customers. Navigating the modern financial services regulatory ecosystem remains a challenge.
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Jun 3, 2024 | 
mondaq.com | Robert Savoie |Aaron Kouhoupt
Bank partnership programs have grown exponentially in recent
years as a collaborative framework for banks and non-depository
institutions to offer innovative and unique products to their
customers.
Navigating the modern financial services regulatory ecosystem
remains a challenge.
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May 14, 2024 | 
mondaq.com | Amy Greenwood-Field |Tiyanna D. Lords |Robert Savoie
In February 2019, the Pennsylvania Department of Banking and
Securities (DoBS) issued public guidance on the applicability of the
Money Transmitter Act (MTA) to virtual currency exchanges by means
of a link entitled "Money Transmitter Guidance on Virtual
Currency" on its Money Transmitter licensing page under the
"Resources" heading.
The MTA defines "money" as "currency or legal
tender or any other product that is generally recognized as a
medium of exchange." See Pa. Const. Stat. tit. 7
§ 6101.
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May 9, 2024 | 
jdsupra.com | Amy Greenwood-Field |Tiyanna D. Lords |Robert Savoie
In February 2019, the Pennsylvania Department of Banking and Securities (DoBS) issued public guidance on the applicability of the Money Transmitter Act (MTA) to virtual currency exchanges by means of a link entitled “Money Transmitter Guidance on Virtual Currency” on its Money Transmitter licensing page under the “Resources” heading. The MTA defines “money” as “currency or legal tender or any other product that is generally recognized as a medium of exchange.” See Pa. Const. Stat. tit. 7 § 6101.
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Apr 22, 2024 | 
mondaq.com | Robert Savoie
In recent years, several state legislatures have enacted
consumer credit laws designed to regulate FinTech companies
operating through partnerships with depository institutions, or
more generally to limit the interest rates charged by those
depository institutions. 2023 was no exception, and this growing
trend should be watched closely by state-chartered depository
institutions and financial services companies.
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Apr 19, 2024 | 
mondaq.com | Rachael Aspery |Robert Savoie
On March 26, 2024, the National Association of Industrial
Bankers (NAIB), American Financial Services Association (AFSA), and
American Fintech Council (AFC) (collectively, "Trade
Associations") filed a complaint in the United States District
Court for the District of Colorado on behalf of their members.
