Innovative Products: Understanding the Regulatory and Enforcement Risks
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We discuss key regulatory issues for innovative products such as buy-now-pay later, longer term installment loans, delay pay, and card-based products (such as “virtual cards.”) We look at the different ways these products can be structured and the impact of these differences on applicable legal requirements, such as disclosures and licensing. We also look at secondary market considerations, legal issues arising from the offering of products through non-bank/bank partnerships including enforcement trends, and recent CFPB developments impacting innovative products.
Participating in the podcast are Michael Guerrero, Lisa Lanham, and Michael Gordon, partners in Ballard Spahr’s Consumer Financial Services Group, and Rinaldo Martinez, Of Counsel in the Group.
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