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A seasoned regulatory and compliance attorney, Carlin brings extensive experience representing financial institutions, fintechs, lenders, payment processors, neobanks, virtual currency companies, and mortgage servicers.

On April 5, the Federal Deposit Insurance Corporation (FDIC) released its Consumer Compliance Supervisory Highlights report, providing a high-level overview of consumer compliance issues identified by the agency during 2022 in its supervisory activities of state non–member banks and thrifts. The report did note that, “[o]verall, supervised institutions demonstrated effective management of their consumer compliance

The Federal Reserve issued a press release announcing its plans for a July debut of FedNow, its service “to facilitate nationwide reach of instant payment services by financial institutions.” As previously discussed here, the FedNow service will provide individuals and businesses the ability to send and receive instant payments through the Federal Reserve’s

Most consumers have signed up for subscriptions, automatic deliveries, or free trials that convert into a paid subscription. In this episode of The Crypto Exchange, Carlin McCrory welcomes colleagues Mark Furletti and Jill Dolan to discuss legal and regulatory developments related to autorenewals — the recurring payments for these subscriptions. Our panel examines state and federal laws pertaining to negative option offers, including Section 5 of the FTC Act; recent actions by state attorneys general on autorenewal and cancellation policies; and how companies can ensure compliance with relevant requirements.

Today, the Federal Trade Commission (FTC) issued a Notice of Proposed Rulemaking with the stated intent to make it easier for consumers to cancel recurring subscriptions and memberships. This rulemaking is part of the FTC’s review of its Negative Option Rule. Amongst other things, the proposed rule would increase the coverage of the Negative Option

Most consumers have signed up for subscriptions, automatic deliveries, or free trials that convert into a paid subscription. In this episode of The Crypto Exchange, Carlin McCrory welcomes colleagues Mark Furletti and Jill Dolan to discuss legal and regulatory developments related to autorenewals — the recurring payments for these subscriptions. Our panel examines state and federal laws pertaining to negative option offers, including Section 5 of the FTC Act; recent actions by state attorneys general on autorenewal and cancellation policies; and how companies can ensure compliance with relevant requirements.

In February, Massachusetts Attorney General Joy Campbell announced a $6.5 million settlement with Safe Home Security, its CEO, and affiliated companies to resolve allegations that their practices violated state consumer protection laws by “trapping Massachusetts consumers in long-term auto renewal contracts” and engaging in illegal debt collection practices, among other activities.

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Chris Willis, co-chair of the CFS Regulatory Practice, Announces the Publication of the 2022 CFS Year in Review and a Look Ahead

Troutman Pepper’s Consumer Financial Services Practice Group consists of more than 120 attorneys and professionals nationwide, who bring extensive experience in litigation, regulatory enforcement, and compliance. Our trial attorneys have litigated thousands of individual and class-action lawsuits involving cutting-edge issues across the country, and our regulatory and compliance attorneys have handled numerous 50-state investigations and nationwide compliance analyses.

We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. Our team has prepared this organized and thorough analysis of the most important issues and trends throughout our industry. We not only examined what happened in 2022, but also what to expect — and how to prepare — for the months ahead.

On March 1, the Consumer Financial Protection Bureau (CFPB) issued an issue spotlight highlighting concerns about prepaid card programs for accessing public assistance benefits. In particular, the spotlight notes “specific recurring issues” related to cash assistance benefits including Social Security, Temporary Assistance for Needy Families (TANF), and unemployment benefits that are provided on prepaid cards.

In the fourth and final segment of our four-part Crypto Year in Review series, Ethan Ostroff, Keith Barnett, and Carlin McCrory discuss how the U.S. Treasury Department — including the Office of Foreign Asset Control (OFAC) and Financial Crimes Enforcement Network (FinCEN) bureaus — functions in the digital asset space. Our speakers examine how these financial services regulators seek to deter criminal activity, such as money laundering, financing of terrorist activities, AML/CFT violations, and sanctions compliance in the digital asset space in 2022, and what we can expect in 2023.