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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 August 15, the Federal Reserve Board (Fed) issued final guidelines, outlining the tiered approach it will use when evaluating the growing requests from fintech firms and cryptocurrency companies for access to master accounts. The guidelines make clear that while requests from institutions with federal deposit insurance will be subject to a streamlined review, institutions

On July 29, the Federal Trade Commission (FTC) filed a complaint and executed a stipulated order with payment processor First American Payment Systems LP (First American) and companies that market its services — Eliot Management Group LLC (Eliot) and Think Point Financial LLC (Think Point) (collectively, the defendants). The FTC alleged that the defendants violated

Please join Consumer Financial Services Partner Chris Willis and his guests and colleagues James Stevens and Carlin McCrory as they discuss the consumer protection and safety and soundness sides of credit union regulation. The discussion includes topics on the National Credit Union Administration’s 2022 consumer protection priorities, loan participations, the 2023 CECL implementation, and the regulatory impact of a recession on consumer loan portfolios held by credit unions.

In this episode of The Crypto Exchange, Troutman Pepper attorneys Keith Barnett and Carlin McCrory welcome Marsha Jones from the Third Party Payment Processors Association to discuss a portion the ENABLERS Act, which proposes to update federal anti-money laundering laws to include payment processors within the definition of “financial institution.” The ENABLERS Act is co-sponsored by Representatives Joe Wilson (R-SC), Tom Malinowski (D-NJ), Maria Elvira Salazar (R-FL), Steve Cohen (D-TN), Abigail Spanberger (D-VA), and Richard Hudson (R-NC). Keith, Carlin, and Marsha discuss the significant ramifications that the ENABLERS Act will have on payments processors if it is passed. This is a must listen for payment processors, banks, and money transmitters!

On May 25, the Federal Trade Commission (FTC) entered a Stipulated Order for Monetary Judgment against Publishers Business Services, Inc. (PBS), and its officers, Brenda Dantuma Schang, Dries Dantuma, Dirk Dantuma, and Jeffrey Dantuma imposing a suspended judgment of $14.47 million.

In 2008, under “Operation Tele-PHONEY,” the FTC joined forces with more than 30 international,

In second episode of The Crypto Exchange, Troutman Pepper Consumer Financial Services Partner Ethan Ostroff welcomes back Keith Barnett and Carlin McCrory to discuss opinions released over the past year involving money transmission and the Money Transmission Act and how they impact stakeholders in the digital asset and payment spaces.

In the first episode of The Crypto Exchange, Troutman Pepper Consumer Financial Services Partner Ethan Ostroff welcomes his colleagues Keith Barnett and Carlin McCrory to discuss recent developments with convenience fees in the payments industry. With both of their practices focusing on payments-related issues, Keith and Carlin take a deep dive into the recent CFPB advisory opinion on convenience fees and how it affects payment processors, money transmitters, and loan servicers. Additionally, they explore how the CFPB’s advisory affects card network rules and how the rules mesh with state laws.

On June 20, the Louisiana Office for Financial Institutions (OFI) proposed a Rule on licensure, registration, and regulation of persons engaging, or planning to engage, in virtual currency business activity in Louisiana. The Rule follows the mandate set by Louisiana’s Virtual Currency Business Act (VCBA), effective August 1, 2020, requiring virtual currency businesses to hold

On June 6, Senators Kirsten Gillibrand (D-NY), member of the Senate Agriculture Committee, and Senator Cynthia Lummis (R-WY), member of the Senate Banking Committee, introduced a draft bipartisan bill, the Responsible Innovation Act (Act), which is Congress’s first attempt to construct an all-encompassing digital asset regulatory framework. The breadth of the Act is sweeping, and

On April 28, bipartisan lawmakers in the U.S. House of Representatives introduced legislation, allowing the Commodity Futures Trading Commission (CFTC) to oversee cryptocurrency spot markets. The legislation intends to create a framework to fill the regulatory gaps between the CFTC and Securities and Exchange Commission (SEC) digital asset marketplace and related regimes.

According to bill