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Keith’s experience representing clients in the financial services industry as a litigation, compliance, regulatory, investigations (internal and regulatory), and enforcement attorney spans 20 years. Keith represents clients against government regulators (CFPB, FTC, SEC, CFTC), industry regulators (FINRA), and private litigants in federal courts, state courts, and before arbitration and administrative law panels in the financial services industry.

On November 2, Consumer Financial Protection Bureau (CFPB) Director Rohit Chopra released a statement on the Report on Stablecoins issued by the President’s Working Group on Financial Markets, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC).

Stablecoins are virtual coins typically pegged to a sovereign currency. The

On October 20, the New York Department of Financial Services (NYDFS) published a notice in the New York State Register announcing that it has issued a proposed regulation to implement S 5470-B, which requires disclosures for commercial financing transactions of $2.5 million or less under a commercial financing agreement.

The notice allows for public

On June 4, the Consumer Financial Protection Bureau (CFPB) issued a frequently asked question and answer guide. Regulation E, in part, establishes limitations on a consumer’s liability and requires investigations of consumers’ claims of unauthorized electronic fund transfers. This FAQ concerns unauthorized transfers governed by Regulation E.

The first and second questions deal with

On May 24, the Conference of State Bank Supervisors (CSBS) released that it is seeking public comment on proposed nationwide licensing requirements for money service businesses (MSBs). The comment period will end on July 23.

The proposal aims to create a national standard for licensure across the MSB industry, while providing state regulators with the

On May 18, the Federal Trade Commission’s (FTC) Acting chairwoman told Congress that the U.S. Chamber of Commerce’s opposition to legislation that would authorize the FTC to obtain monetary remedies under Section 13(b) of the FTC Act was based on “numerous misstatements and faulty premises.” Chairwoman Slaughter’s comments highlight the FTC’s concern that the Supreme

On May 17, the Consumer Financial Protection Bureau (CFPB) announced a settlement with DMB Financial LLC, a Massachusetts-based debt-settlement company.

In its complaint, the CFPB alleged that DMB Financial violated the Telemarketing Sales Rule (TSR) and the Consumer Financial Protection Act of 2010 (CFPA) by charging illegal fees and misleading consumers about its business practices.

On May 12, the Senate Commerce Committee voted overwhelmingly to move forward with Lina Khan’s nomination to the Federal Trade Commission (FTC), which suggest that Khan is likely to be confirmed as an FTC commissioner by the full Senate. Khan has been a critic of big tech and advocate of competitive markets, as we previously

The Department of Financial Protection and Innovation (DFPI) of California entered a settlement agreement with Chime Financial, Inc. (Chime), a neobank company that is not licensed to operate as a bank or otherwise exempt from licensure, but works with banking partners to issue consumer banking products. The DFPI found that Chime potentially violated California Financial

The Federal Trade Commission (FTC) is acting swiftly to restore its authority to obtain consumer redress under Section 13(b) of the FTC Act after the Supreme Court’s recent decision in AMG Capital Management, LLC v. FTC, discussed in our blog post here, rejecting the agency’s longstanding position that Section 13(b) authorizes monetary remedies.

Additional authors: Robin P. Sumner and Samuel D. Harrison

On April 22 the Supreme Court held in AMG Capital Management, LLC v. FTC[1] that the Federal Trade Commission (FTC) does not have authority under the Federal Trade Commission Act Section 13(b) to seek, nor a court to award, equitable monetary relief, such as restitution