On March 16, 2022, the Consumer Financial Protection Bureau (“CFPB”) announced that it would combat perceived discrimination in the consumer financial marketplace by expanding its authority to target unfair, deceptive or abusive acts or practices (“UDAAPs”). Specifically, the CFPB directed examiners to scrutinize whether potentially discriminatory conduct may be unfair. The CFPB simultaneously published an updated exam manual for UDAAPs…
On March 17, 2022, Sen. Elizabeth Warren (D-MA) and other Democrats introduced the Digital Asset Sanctions Compliance Enhancement Act of 2022. Also that day, the U.S. Senate Committee on Banking, Housing and Urban Affairs (“Senate Banking Committee”) hosted a hearing entitled “Understanding the Role of Digital Assets in Illicit Finance.” I. Digital Asset Sanctions Compliance Enhancement Act of 2022 Sens.…
On March 8, 2022, the Federal Reserve Board (“FRB”) issued for public comment proposed supplemental guidelines (“Supplemental Proposed Guidelines”) for Federal Reserve Banks (“Reserve Banks”) to use in evaluating requests for master accounts and access to Reserve Bank financial services (“Fed Accounts and Services”).[1] The Supplemental Proposed Guidelines would build on the proposed guidelines the FRB issued for public comment…
On March 15, 2022, the Federal Trade Commission (“FTC”) announced a proposed consent order in resolution of an administrative complaint filed against payment processor Electronic Payment Systems (“EPS”) and its individual owners, John Dorsey and Thomas McCann, alleging violations of the Federal Trade Commission Act’s prohibition against unfair and deceptive acts or practices and the Telemarketing Sales Rule. According to…
Yesterday, President Biden signed an Executive Order (the “Order”) outlining, as described in the accompanying Fact Sheet, a “whole-of-government approach” to harness the benefits, and address the potential risks, of digital assets, including risks to consumers, financial stability, national security and the climate. The Order acknowledges the explosive growth in non-state issued digital assets and the rapid development of central…