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Carlin is a regulatory, compliance, and payments attorney with experience representing financial institutions, fintechs, lenders, debt collectors, payment processors, neobanks, virtual currency companies, and mortgage servicers.

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 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 February 4, the Department of the Treasury (Treasury) released the “Study of the Facilitation of Money Laundering and Terror Finance through the Trade in Works of Art” (Study). The Study assesses the various risks of the high-value art market based on its propensities for money laundering and illicit financing.

Specifically, the Study

On February 8, a Northern District of California judge ruled on cross motions for summary judgment filed by the states of California, Illinois, and New York (plaintiffs) and the Office of the Comptroller of the Currency and Michael Hsu in his capacity as acting comptroller of the currency (collectively, the OCC) on the validity of

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

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,

On January 14, a D.C. federal judge granted the Consumer Financial Protection Bureau’s (CFPB) motion to dismiss a case filed by the National Association for Latino Community Asset Builders (NALCAB), after the NALCAB contested the CFPB’s decision to repeal the ability to repay requirements.

The Payday Rule has been both modified and challenged since its

On December 15, a district judge in California approved a settlement between MyLife.com, Inc. (MyLife), its CEO Jeffrey Tinsley, and the Department of Justice (DOJ) on behalf of the Federal Trade Commission (FTC). The settlement bans MyLife and Tinsley from engaging in deceptive negative option marketing and requires them to pay $21 million due to

Colorado and Delaware have enacted new laws for automatic renewal or negative options offers. The new laws became effective January 1, 2022. Illinois already has a law on the books related to automatic renewals but has recently made a few minor amendments to it.

Colorado. Companies must disclose the following in a clear and conspicuous