Photo of Carlin McCrory

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

In this special crossover edition of the Payments Pros and Crypto Exchange podcast, Carlin McCrory is joined by colleagues Alex Barrage and Ethan Ostroff to discuss recent legislative updates surrounding payment stablecoins. The group begins by exploring the advantages of payment stablecoins, such as their 24/7 availability and programmability, and the merits of having robust competition for stablecoin issuance and use cases.

In this special crossover edition of the Payments Pros and Crypto Exchange podcast, Carlin McCrory is joined by colleagues Alex Barrage and Ethan Ostroff to discuss recent legislative updates surrounding payment stablecoins. The group begins by exploring the advantages of payment stablecoins, such as their 24/7 availability and programmability, and the merits of having robust competition for stablecoin issuance and use cases.

On April 7, DailyPay, LLC, an employer-integrated earned wage access (EWA) provider, filed a lawsuit against New York Attorney General Letitia James, seeking declaratory relief to prevent the enforcement of state and federal laws that the company argues do not apply to its business model. The case, filed in the U.S. District Court for the Southern District of New York, centers on the classification of DailyPay’s on-demand pay (ODP) product, which allows workers to access their earned wages before the traditional payday.

The Conference of State Bank Supervisors (CSBS), a nationwide organization of state banking and financial regulators from all 50 states, the District of Columbia, and U.S. territories, has raised significant concerns regarding the current draft of the Stablecoin Transparency and Accountability for a Better Ledger Economy (STABLE) Act.

In this episode of Payments Pros, host Carlin McCrory discusses a recent consent order between Patriot Bank and the Office of the Comptroller of the Currency (OCC) following a $27 million loss. The order addresses unsafe practices and legal violations, focusing on prepaid card program oversight. Key areas of concern include the need for a strategic plan, evaluation of internal operations, and staffing requirements. The bank must also enhance its Customer Identification Program (CIP) and ensure adequate monitoring of third-party program managers.

On March 20, the Arkansas governor signed into law Arkansas Act 347, known as the Earned Wage Access Services Act. Sponsored by Representative David Ray (R) and Senator Ben Gilmore (R), this legislation aims to regulate earned wage access (EWA) providers. Notably, “providers” is defined to include a person engaged in the business of offering earned wage access, but not an employer that advances a portion of earned wages directly to employees or independent contractors.

In the latest episode of Payments Pros, hosts Keith Barnett and Carlin McCrory discuss the latest FinCEN and OFAC guidance on virtual currency transactions, specifically tailored for companies in the payments industry. They explore when businesses need to register as money services businesses (MSBs) under federal law and discuss the roles of users, exchangers, and administrators of virtual currencies. Carlin provides a detailed look at the regulatory requirements for both centralized and decentralized virtual currencies.

The Utah Legislature has passed H.B. 279, known as the Earned Wage Access Services Act. Sponsored by Representative A. Cory Maloy (R) and Senator Chris H. Wilson (R), this legislation aims to regulate earned wage access (EWA) providers. Notably, “providers” is defined to include a person engaged in the business of offering earned wage access, but not an employer that advances a portion of earned wages directly to employees or independent contractors. If signed by the Governor, the Act will take effect on May 7, 2025.