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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.

This article was republished on insideARM on March 28, 2022.

On March 15, the Federal Trade Commission (FTC or Commission) released a consent agreement with Electronic Payment Systems and its owners John Dorsey and Thomas McCann (collectively, EPS) for allegedly opening credit card processing merchant accounts for fictitious companies on behalf of Money Now Funding

On March 11, Britain, Canada, France, Germany, Italy, Japan, and the United States (collectively, the G7) announced more sanctions against Russia, including first-time sanctions specific to virtual assets. The White House also announced that the Department of the Treasury would issue “new guidance [that] will continue to make clear that Treasury’s expansive actions against Russia

The Board of Governors of the Federal Reserve System (the Board) recently issued a supplemental notice and request for comment to the guidelines proposed in May 2021 for use by Federal Reserve Banks (Reserve Banks) in evaluating requests to access Federal Reserve accounts and payment services, in an effort to ensure that Reserve Banks use

On March 9, President Biden signed an Executive Order (the Order) to establish the first comprehensive federal digital asset strategy for the U.S., which would promote digital asset innovation while balancing benefits and associated risks. The order directs the Justice Department, U.S. Department of the Treasury, the Board of Governors of the Federal Reserve System,

On February 21, President Biden issued an executive order blocking property of certain persons, and prohibiting transactions regarding Russia’s invasion of the Ukraine. The following day, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) issued restrictions on activities with Russian individuals and entities. On February 25, these lists were updated to include political leaders

On February 25, the New York State Department of Financial Services (NYDFS) issued Guidance to all individuals and entities subject to its regulation due to the rapidly evolving situation in Ukraine, following the Russian invasion and the imposition of sanctions, in particular businesses engaged in virtual currency activity. Relatedly, on March 2, Governor Hochul announced

On February 14, the Consumer Financial Protection Bureau (CFPB) updated its Supervision and Examinations Manual to reflect changes it made to the Remittance Transfer Rule (Rule) in a final rule published on June 5, 2020. The changes made to Subpart B of Regulation E, effective July 21, 2020, (1) increased the Rule’s safe harbor for

On January 26, the Consumer Financial Protection Bureau (CFPB or Bureau) announced its request for the public to share its input on “exploitative junk fees charged by banks and financial companies” to form its rulemaking and guidance agenda, along with its enforcement priorities. The CFPB’s press release included a link to its “Request for Information

2021 was a transformative year for the consumer financial services world. As we navigate an unprecedented volume of industry regulation, Troutman Pepper is uniquely positioned to help its clients find successful resolutions and stay ahead of the curve.

In this report, we share developments on auto finance, background screening, bankruptcy, consumer class actions, consumer

On January 18, the Consumer Financial Protection Bureau (CFPB) filed a proposed final judgment and order in its March 2021 lawsuit against BrightSpeed Solutions, a third-party payment processor, and its founder, Kevin Howard. If the court enters the final judgment and order, both BrightSpeed and Howard will be permanently barred from multiple consumer financial industries,