The Office of the Comptroller of the Currency (“OCC”) released another Interpretive Letter relating to a nation bank’s use of cryptocurrency and blockchain technology. Interpretive Letter 1174 provides that national banks and federal savings associations may use independent node verification networks (“INVN”) and stablecoins to carry out permissible payment activities…Read More
Month: January 2021
OCC ISSUES INTERPRETATIVE LETTER ON PREEMPTION UNDER THE DODDFRANK ACT
On December 18, 2020, the chief counsel of the Office of the Comptroller of the Currency (“OCC”) published a letter detailing the OCC’s comprehensive interpretation of the federal preemption standard and related procedural requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) (codified at 12 U.S.C. § 25b, “Section 25b”). See OCC Chief Counsel’s Interpretation: 12 U.S.C. § 25b, Interpretation Letter No. 1173 (Dec. 18, 2020)…Read More
CFPB DECLARES CERTAIN EARNED WAGE ACCESS PROGRAMS ARE NOT CREDIT SUBJECT TO REGULATION Z
Recently, the Consumer Financial Protection Bureau (“CFPB”) released two opinions that clarify the types of earned wage access (“EWA”) programs that do not involve the offering or extension of “credit” regulated by Regulation Z.
On November 30, the CFPB issued an advisory opinion to resolve regulatory uncertainty regarding the applicability…Read More