CFPB, Federal Agencies, State Agencies, and Attorneys General
The CFPB, in a notice published in the Federal Register on September 27, 2022, announced that it was rescinding its No-Action Letter and Compliance Assistance Sandbox policies (Policies). The rescission was effective on September 30, 2022.
In the notice, the CFPB stated:
… Continue ReadingThe CFPB determined that the Policies do not advance their stated objective of facilitation consumer-beneficial innovation.
On May 25, 2022, my colleagues, Mike Gordon, John Culhane and Ron Vaske published a blog which reported on a press release issued by the CFPB on the prior day entitled “CFPB Launches New Effort to Promote Competition and Innovation in Consumer Finance.” The blog stated:
… Continue ReadingIn its press release, the CFPB states that “[a]fter a review of these programs [the No Action Letter (NAL) and Compliance Assistance Sandbox (CAS) programs], the agency concludes that the initiatives proved to be ineffective and that some firms participating in these programs made public statements indicating that the Bureau had conferred benefits upon them that the Bureau expressly did not.”
The CFPB and Utah AG’s Office have announced that they will hold the first joint office hours as part of the American Consumer Financial Innovation Network (ACFIN). The joint office hours will be held on January 30, 2020 in Salt Lake City, Utah.
The CFPB announced ACFIN’s creation last September, in conjunction with finalizing revisions to its trial disclosures and no-action letter policies and its proposal to create a new fintech sandbox policy. … Continue Reading
Paul Watkins, Director of the CFPB’s Office of Innovation, joined Ballard Spahr partners Alan Kaplinsky and James Kim yesterday for a discussion of the CFPB’s final innovation policies. Alan leads the firm’s Consumer Financial Services Group and James is a co-leader of the firm’s inter-disciplinary Fintech Team.
Last month, the CFPB finalized its proposed revisions to its trial disclosures and no-action letter (NAL) policies and also finalized its proposal to create a new FinTech sandbox policy. … Continue Reading
The CFPB has finalized its proposed revisions to its Policy to Encourage Trial Disclosure Programs” (TDP Policy) and policy on “no-action” letters (NAL Policy) and has also finalized its proposal to create a new “product sandbox” policy. In addition, the CFPB has announced the creation of the American Financial Innovation Network (ACFIN) to facilitate coordination between the CFPB, other federal regulators, and state regulators and the CFPB’s issuance of the first NAL under the revised NAL Policy. … Continue Reading
Utah is now taking applications for its new regulatory sandbox program. In this podcast, we interview Rep. Marc Roberts, the sponsor of the bill that created the program, and Bryan Cowley, the Utah regulator who will oversee the program’s administration. Topics discussed include the bill’s history and objectives, implementation plans, reciprocity with other sandbox programs, the physical location requirement, confidentiality of applicant information, and liability exposure.… Continue Reading
Utah Governor Gary Herbert signed H.B. 378, Regulatory Sandbox, into law on March 25, 2019. This bill created the nation’s third regulatory sandbox program for fintechs, after Arizona, which enacted sandbox legislation in March 2018, and Wyoming, which enacted sandbox legislation in February of this year.
Regulatory sandboxes are laboratories for the development of innovative technologies in an environment that is free from onerous government restrictions. … Continue Reading
Earlier this year, Wyoming became the second state to create a financial technology (fintech) sandbox by enacting the “Financial Technology Sandbox Act” (Sandbox Act). (Arizona was the first state to create a fintech sandbox and we will soon be publishing a blog post about Utah’s new fintech sandbox.) The provisions requiring Wyoming’s Banking Commissioner and Secretary of State to adopt implementing regulations became effective on February 19, 2019. … Continue Reading
The Office of the Comptroller of the Currency (OCC) has opened its own “sandbox” through a Proposed Innovation Pilot Program (Program) designed to promote its innovation initiatives, add value through proactive supervision, and continue its objective to lead fintech innovation expansion. The comment period for the Program is open until June 14, 2019.… Continue Reading
“Disclosure Sandbox.” In September 2018, the Bureau proposed significant revisions to its “Policy to Encourage Trial Disclosure Programs” which sets forth the Bureau’s standards and procedures for exempting individual companies, on a case-by-case basis, from applicable federal disclosure requirements to allow those companies to test trial disclosures.
Last week, the CFPB added the following update to its blog post about the proposal:
The original headline [which referred to “companies”] suggested that the proposed Disclosure Sandbox would be open only to “fintech companies.” … Continue Reading
