Fintech and stuff. General Counsel at Hometap. No legal advice here, just idle chit chat based on lots of years in the biz.
Connecticut, USA
Joined February 2011
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When I worked at the CT DOB, one of the oddities of CT law is that the DOB also has jurisdiction over rental security deposits.
There weren’t many cases, but 100% of those cases that did exist involved small, not at all “corporate” landlords. Small owners were worse.
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CFPB issues new advisory opinion on EWA
What a wild ride the regulatory world of EWA has been. Following the issuance of guidance in 2020, a rescission of that guidance in 2025 and then a rescission of the rescission, the CFPB today has re-issued new guidance (in next tweet)
On first pass, EWA programs that allow employees to access wages that they’ve already earned, and that:
1) are non-recourse;
2) repaid through payroll deduction; and
3) do not charge interest or fees;
Do not constitute “credit”
Interesting article on the potential expansion of deposit insurance limits from two very … different … perspectives which, nevertheless, share the same concerns
Why do a progressive academic and conservative banker both think raising deposit insurance limits to $10M is a bad idea? Read what @JillCastilla and I wrote in @barronsonline
barrons.com/articles/higher-…
Very interesting look at impact on banks of Stablecoins. Worth a read (or at least this summary)
Jesse Silverman retweeted
Only read a few sections so far, but this is EXCEPTIONALLY useful to practitioners in the space. And I can’t think of how rarely I’ve said that about a law professor’s paper
Kudos @tphillips
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Looks like the CFPB is back in the game …
🚨We are so back!🚨 "Here is something to be thankful for this Thanksgiving: The Federal Reserve System has 𝙧𝙚𝙩𝙪𝙧𝙣𝙚𝙙 𝙩𝙤 𝙥𝙧𝙤𝙛𝙞𝙩𝙖𝙗𝙞𝙡𝙞𝙩𝙮. It appears to be on track for the combined profits [of] over $2 billion in the current quarter." tinyurl.com/2h5em63u @billnelson2x2
Fresh off Fintech NerdCon, I’m struck by how many conversations I had about the Colorado DIDMCA decision and its impact on fintech and bank partnerships
The biggest takeaway is that we still don’t know the extent of the impact to those partnerships, but it’s not zero
On a small policy note, it is fascinating to watch this play out. In many states, consumer credit and banking are under the Department. So this is an internal battle between consumer credit, which wants DIDMCA, and the banking division which doesn’t want to devalue state charters