CFPB's new strategic plan, regulatory risks of digital currency, and more in this issue of Consumer Financial Services Practice Digest

3 min

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CFPB Strategic Plan: New Management, New Priorities

The CFPB has released its 2018-2023 Strategic Plan, a document that sets out the Bureau's mission, goals, and objectives for the next five years. The new Strategic Plan reflects the policy positions of the administration and new acting director of the Bureau—a core principle of which is to "go no further" than the CFPB's statutory responsibilities.

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The White House, U.S. Supreme Court Building, and U.S. Capitol Building

Will the Federal Government "Preempt" State Consumer Protection Efforts?

The prevailing winds seem to indicate that we are well into President Trump's era of deregulation, which means certain activity will slow down at federal regulatory and enforcement agencies, such as the CFPB. However, some of this slowdown—at least on the enforcement side—will be picked up by state attorneys general and other state regulators. While a number of states from New York to California have expressed their willingness to fill in for anything left out of the reprioritized CFPB, the Trump administration may put up some roadblocks. In some instances the states may be able to step into the federal government's shoes, but in others the states may encounter arguments about federal preemption.

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Playing Your Best Hand When Dealt a State Attorney General Investigation

Venable attorneys, Jonathan L. Pompan and Hon. Mark L. Pryor, former Arkansas State Attorney General and U.S. Senator, joined a panel discussion, "Playing Your Best Hand When Dealt a State Attorney General Investigation," at the 2018 Receivables Management Association Annual Conference. State Attorneys General have become increasingly involved in consumer financial services investigations and enforcement. Whether involving a single state Attorney General or multiple Attorneys General, investigations and litigation can lead to high costs, administrative burdens, distractions, and reputation damage. Often there may be parallel investigations by federal agencies, and risks and exposure from private litigation. Learn from seasoned attorneys at the front lines of defending companies against investigations and litigation brought by State Attorneys General.

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CSBS Announces Streamlined Money Transmitter Application Process in Seven States

As a first step in reducing the burden of applying for state financial services licenses, the CSBS announced that seven states have agreed to work together to streamline the process of applying for money transmission licenses: Georgia, Illinois, Kansas, Massachusetts, Tennessee, Texas, and Washington. CSBS expects additional states to join the agreement in the future.

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Filthy Lucre: Regulatory Risks of Digital Currency, Loot Crates, and Other Video Game Monetization Strategies

Over the past few years, video game developers have been at the forefront of integrating cryptocurrencies and other payment technologies into their games to create realistic, seamless, and interactive worlds. While the gaming industry has moved ahead quickly, federal and state regulators are taking a much closer look at how these technologies fit within existing legal frameworks.

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credit cards

Say Goodbye to Credit Card Signature Requirements

The days of signing your grocery receipt may be over soon, as the four major credit card brands (American Express, Discover, Visa, and Mastercard) are each making efforts to do away with signatures for various credit card transactions. The extent and geographic reach of these changes, however, are different for each brand, but one commonality is that the changes will begin in April 2018.

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March 1, 2018: "Investing in Compliance as a Strategy to Prevent or Resolve Government Investigations," at Venable LLP's New York Office

March 1, 2018: "The New CFPB" an Electronic Transactions Association (ETA) Spotlight Call

March 7, 2018: "Ensuring Effective Compliance in Lead Generation," at the LeadsCon 2018 Las Vegas Conference

April 25-27, 2018: "Consumer Financial Services Legal and Regulatory Update," at the 2018 Financial Counseling Association

May 11, 2018: "Hot Topics in Financial Services Litigation and Enforcement," at ACI's Women Leaders in Financial Services Law and Compliance event