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On October 11, California’s Office of Administrative Law (“OAL”) approved the Department of Financial Protection and Innovation’s (“DFPI’s”) registration rulemaking for providers of the following products:

• Income-Based Advances (more commonly known as earned wage access (“EWA”) products);
• Private Postsecondary Education Financing (including income share agreements (“ISAs”);
• Debt Settlement Services; and
• Student Debt Relief Services.

On October 29, New Jersey Attorney General Matthew Platkin and the state’s Division on Civil Rights (DCR) released a report detailing the findings of a multi-year investigation into Republic First Bank (Republic) and its alleged mortgage redlining practices. According to the report, the investigation revealed that Republic engaged in a pattern or practice of redlining against Black, Hispanic, and Asian communities in New Jersey, in violation of the New Jersey Law Against Discrimination.

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As we get accustomed to the idea of a hybrid workforce, I’m reminded that a hybrid approach to third party auditing can also be appropriate, allowing organizations to maintain effective oversight while optimizing time, resources and the depth of inspection based on the vendor’s risk level and function.

In a recent enforcement action, the Consumer Financial Protection Bureau (CFPB) has held VyStar Credit Union—formerly known as JAX Navy Federal Credit Union—accountable for a disastrous online banking transition that harmed its members. In May 2022, VyStar launched a new virtual banking system that was fraught with technical issues, leaving thousands of members unable to access basic banking services for weeks. Some features remained unavailable for over six months, resulting in significant disruptions and fees for impacted families.

Today, the Consumer Financial Protection Bureau (CFPB) took action against VyStar Credit Union for harming consumers through its botched rollout of a new online banking system. In May 2022, VyStar transitioned to a new, dysfunctional online banking platform that made it difficult for credit union members to perform basic banking functions for weeks, with some features unavailable for more than six months. Families incurred fees and costs as a result of these problems. The CFPB is ordering VyStar to ensure that all consumers are made whole.