Stephen Krebs is an associate in the firm’s Financial Services & Products Group and a member of its payment systems and bank regulatory teams. He advises clients on the laws and regulations affecting the development and delivery of payment products and services, including consumer protection statutes, anti-money laundering rules, and state licensing obligations. He also represents industry participants during the rulemaking process through the preparation of comment letters and other written analyses. Mr. Krebs has experience providing regulatory counsel with respect to a broad range of banking and payment products, including credit, debit and prepaid cards; ACH and wire transfer transactions; and mobile payment services.
Mr. Krebs received his J.D., with honors, in 2010 from the George Washington University Law School, where he served as a member of the George Washington International Law Review and as a Dean’s Fellow for the Legal Research and Writing Program. He received his B.A. in 2003 from the University of North Carolina at Chapel Hill.
- Counseled numerous bank clients on the impact of the Dodd-Frank Act and implementing regulations, including the “remittance transfer rules” and other regulations promulgated by the Consumer Financial Protection Bureau.
- Counseled a large prepaid card provider on a wide range of regulatory issues, including compliance with Regulation E, UDAAP and anti-money laundering requirements.
- Drafted a variety of letters responding to requests for comment relating to regulations proposed under the Dodd-Frank Act, including a comment letter jointly submitted by ten financial services industry associations.
This advisory discusses the Consumer Financial Protection Bureau’s proposed changes to Regulation P, the rule that implements the consumer financial privacy provisions of the Gramm-Leach-Bliley Act.
May 12, 2014
"Regulatory & Litigation Update," FinTech Law Report, Vol. 17, No. 2, March/April 2014.
USPS Inspector General issues report on providing non-bank financial services for the underserved; CFPB proposes rule to supervise nonbank international money transfer providers; FinCEN issues administrative rulings regarding virtual currency miners and investors; government accountability office publishes report on college debit card programs; CFPB urges credit card companies to make credit scores available to consumers; D.C. Circuit Court upholds Federal Reserve Board Regulation II; and Seventh Circuit rules for Target Corp. on TILA challenge to credit card upgrade.
This advisory discusses OCC proposed guidelines that would establish minimum standards for the design and implementation of a risk governance framework for certain national banks and federal savings associations (“Proposed Guidelines”). The Proposed Guidelines were developed out of the “heightened expectations” the OCC implemented in its supervision of large banks following the financial crisis. The OCC notes that “[a]chievement and maintenance of the heightened expectations should help lessen the impact of future economic downturns on large institutions.”
January 21, 2014