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Mark Brnovich, the Arizona Attorney General, recently issued an opinion regarding whether earned wage access (EWA) products are “consumer lender loans” under the state’s Consumer Lenders Act (CLA) such that a person who makes, procures, or advertises an EWA product must be licensed as a “consumer lender.”  The AG concluded that an EWA product offered as a no-interest and non-recourse product is not a “consumer lender loan” under the CLA.… Continue Reading

Our guest for this week’s podcast is Paul Watkins, Director of the CFPB’s Office of Innovation.  Paul formerly worked in the Arizona Attorney General’s office where he was in charge of fintech initiatives and led the state’s successful efforts to create the first “regulatory sandbox” in the United States which allows new financial technologies and products to be tested in a controlled environment with reduced regulatory risk.… Continue Reading

We talk with Evan Daniels, Fintech Counsel in the Arizona Attorney General’s office, about Arizona’s first-in-the-nation Fintech sandbox and how it is being used to drive innovation in consumer financial services.  We also discuss how the CFPB’s current push to encourage innovation interacts with state efforts, such as those in Arizona.… Continue Reading

In August 2018, Arizona began accepting applications for its regulatory sandbox that “enables a participant to obtain limited access to Arizona’s market to test innovative financial products or services without first obtaining full state licensure or other authorization that otherwise may be required.”  The state’s Attorney General is responsible for the application process and oversight of the sandbox. … Continue Reading

On August 3, 2018, Arizona began accepting applications for its regulatory sandbox that “enables a participant to obtain limited access to Arizona’s market to test innovative financial products or services without first obtaining full state licensure or other authorization that otherwise may be required.”  In March 2018, Arizona’s Governor signed into law legislation directing the state’s Attorney General to create the sandbox. … Continue Reading

Arizona Governor Doug Ducey signed HB 2154 into law on April 11, 2018, amending and strengthening the state’s data breach notification law. Notably, the amended law significantly expands the definition of “personal information” to include a number of new data elements, including online account credentials, certain health information, and biometric data used to authenticate an individual when the individual accesses an online account. … Continue Reading

Arizona’s Governor recently signed into law legislation that directs the state’s Attorney General to establish a “regulatory sandbox program” for the purpose of “enabl[ing] a person to obtain limited access to the market in this state to test innovative financial products or services without obtaining a license or other authorization that would otherwise apply.” … Continue Reading