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California Department of Business Oversight December 2019 Actions

USA - January 10 2020 The California Department of Business Oversight (CDBO) recently concluded that the point of sale consumer financing programs offered by Sezzle, Inc...

Kerry Ann Nilsen, David E.Teitelbaum, James A. Huizinga, John K. Van De Weert.

FDIC Proposes Rule on Brokered Deposits

USA - December 30 2019 On December 12, 2019, the Federal Deposit Insurance Corporation (FDIC) issued a notice of proposed rulemaking (NPR)1 proposing changes to the FDIC’s...

Michael D. Lewis, David E.Teitelbaum, Patrick O’Keefe.

Conference of State Bank Supervisors Releases Draft Model MSB Law

USA - October 17 2019 On October 10, 2019, the Conference of State Bank Supervisors (CSBS) published a draft model money services business (MSB) law, which, once finalized...

David E.Teitelbaum.

Financial Crimes Enforcement Network Guidance Regarding Convertible Virtual Currencies, Wallets, ICOs, DApps and More

USA - May 15 2019 On May 9, 2019, the Financial Crimes Enforcement Network (FinCEN) issued guidance relating to how the Bank Secrecy Act (BSA) and its implementing...

Lilya Tessler, Verity A. Van Tassel Richards, David E.Teitelbaum, Stanley J. Boris.

Court Permits New York State Department of Financial Services Suit Against Office of the Comptroller of the Currency to Proceed

USA - May 6 2019 On May 2, 2019, a federal district court judge denied a motion to dismiss filed by the U.S. Office of the Comptroller of the Currency (OCC) in the...

Geoffrey F. Aronow, Lilya Tessler, David E.Teitelbaum, Michael S. Sackheim, Stanley J. Boris.