Lauren Kelly (LK) Greenbacker

Lauren Kelly (LK) Greenbacker

Washington, District of Columbia, United States
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About

Alumna of UNC-Chapel Hill (2011) and the University of Pennsylvania School of Law…

Activity

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Experience

  • Paul Hastings Graphic

    Paul Hastings

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    Atlanta, GA

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    Washington, DC

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    Philadelphia, PA

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    Washington D.C. Metro Area

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    McLean, VA

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Education

  • University of Pennsylvania Carey Law School Graphic

    University of Pennsylvania Law School

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    Wharton Certificate in Management, The Wharton School (2014)

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    Activities and Societies: Phi Beta Kappa Sigma Delta Pi Scholars' Latino Initiative Pi Beta Phi Blank Canvas

Publications

  • FinCEN Guidance Highlights Continued Regulatory Focus on Anti-Money Laundering Risks Posed by MSB Agents

    Stay Current: A Client Alert from Paul Hastings

    In recent years, the federal banking agencies and the Financial Crimes Enforcement Network (“FinCEN”) have continued to sharpen their focus on the application and enforcement of the Bank Secrecy Act (“BSA”) and anti-money laundering (“AML”) laws. This supervisory attention, which has historically focused on banking institutions, has increasingly turned to oversight and enforcement of BSA/AML issues related to nonbank financial institutions. Consistent with this trend, FinCEN recently issued new…

    In recent years, the federal banking agencies and the Financial Crimes Enforcement Network (“FinCEN”) have continued to sharpen their focus on the application and enforcement of the Bank Secrecy Act (“BSA”) and anti-money laundering (“AML”) laws. This supervisory attention, which has historically focused on banking institutions, has increasingly turned to oversight and enforcement of BSA/AML issues related to nonbank financial institutions. Consistent with this trend, FinCEN recently issued new guidance reiterating how the principals of money services businesses (“MSB(s)”) are expected to manage AML risks associated with activities performed by their agents (the “Guidance”). The Guidance emphasizes federal regulators’ focus on ensuring financial institutions maintain appropriate oversight over third parties, and more specifically reinforces FinCEN’s focus on agents of MSBs over the past several years.

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  • Virtual Currency and Regulation

    The Review of Securities & Commodities Regulation

    Federal, State, and EU regulators are directing attention to virtual currencies, focusing on risks to consumers, cybercrime, and AML compliance, among others. The authors review the steps being taken by the CFPB, FinCEN, the Federal Reserve, and the FTC. They also discuss state guidance from New York, Texas, and Kansas, and the European Banking Authority’s formal opinion on the risks and need for regulation in the EU.

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  • The California Finance Lenders Law: Gaining Traction with Both Lenders and Regulators

    Stay Current: A Client Alert from Paul Hastings

    The California Finance Lenders Law (“CFLL”) imposes licensing requirements on all entities seeking to make or broker loans – whether consumer or commercial loans – in the State of California. Though most traditional lenders are exempt from the CFLL, many alternative lenders may not engage in lending activities without obtaining a finance lenders license from the California Department of Business Oversight (“DBO”). Obtaining a CFLL license provides non-traditional lenders – including foreign…

    The California Finance Lenders Law (“CFLL”) imposes licensing requirements on all entities seeking to make or broker loans – whether consumer or commercial loans – in the State of California. Though most traditional lenders are exempt from the CFLL, many alternative lenders may not engage in lending activities without obtaining a finance lenders license from the California Department of Business Oversight (“DBO”). Obtaining a CFLL license provides non-traditional lenders – including foreign lenders – a path of entry into the California lending market. However, as the CFLL has begun to garner more attention from regulators, an entity engaging in any kind of lending in California should closely analyze the parameters of the CFLL to determine whether the entity is exempt from the CFLL or that it is properly licensed and in compliance with the law’s requirements.

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  • Is Your Business Ready to Comply with the Final Amended Department of Defense Military Lending Act Regulation?

    Stay Current: A Client Alert from Paul Hastings

    On October 1, 2015, the Department of Defense (“DOD”) final rule amending its implementing regulation under the Military Lending Act (“MLA”) goes into effect (the “MLA Rule”). Notably, the new rule extends the Military Lending Act to all types of small dollar or payday loans, vehicle titles, refund anticipation loans, deposit advance and installment loans, unsecured open-end lines of credit, and even credit cards made to service members and their families. With these changes, the Department of…

    On October 1, 2015, the Department of Defense (“DOD”) final rule amending its implementing regulation under the Military Lending Act (“MLA”) goes into effect (the “MLA Rule”). Notably, the new rule extends the Military Lending Act to all types of small dollar or payday loans, vehicle titles, refund anticipation loans, deposit advance and installment loans, unsecured open-end lines of credit, and even credit cards made to service members and their families. With these changes, the Department of Defense—the stealth bank regulator—has expanded the types of closed-end and open-end credit products that will be covered by the provisions of the Military Lending Act, and placed a significant compliance burden on lenders who seek to offer certain consumer credit products to military families.

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  • Treasury Department Seeks Comments on Online Marketplace Lending

    Stay Current: A Client Alert from Paul Hastings

    In light of the recent expansion of online marketplace lending, the United States Department of the Treasury (the “Treasury Department”) has issued a request for information (“RFI”) seeking public comment on alternative online lending. Specifically, the Treasury Department is seeking input on the business models and products that alternative lenders offer to small business and consumers, the potential for alternative lending to provide access to credit to underserved markets, and the extent to…

    In light of the recent expansion of online marketplace lending, the United States Department of the Treasury (the “Treasury Department”) has issued a request for information (“RFI”) seeking public comment on alternative online lending. Specifically, the Treasury Department is seeking input on the business models and products that alternative lenders offer to small business and consumers, the potential for alternative lending to provide access to credit to underserved markets, and the extent to which changes are needed in the regulatory framework in order to properly manage the risk of this growing market segment.

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  • CFPB’s Public Complaint Database Likely to Amplify Consumer Voice But Muffle Effective Provider Responses

    Stay Current: A Client Alert from Paul Hastings

    The Consumer Financial Protection Bureau recently issued its final policy statement enabling consumers to post on the CFPB’s web-based public consumer complaint database about consumer financial services in narrative format. By making such firsthand narratives of the consumer experience publicly available, the CFPB seeks to assist consumers in making well-informed financial decisions. However, the minimal procedures in place for verifying the accuracy of information alleged in such complaints…

    The Consumer Financial Protection Bureau recently issued its final policy statement enabling consumers to post on the CFPB’s web-based public consumer complaint database about consumer financial services in narrative format. By making such firsthand narratives of the consumer experience publicly available, the CFPB seeks to assist consumers in making well-informed financial decisions. However, the minimal procedures in place for verifying the accuracy of information alleged in such complaints, the limited opportunity afforded to providers to respond, and the failure to ensure that published information and data is statistically representative of the consumer experience, may compromise the CFPB’s efforts with respect to this goal.

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  • CFPB Proposes Comprehensive New Regulatory Regime for Prepaid Cards

    Stay Current: A Client Alert from Paul Hastings

    Discusses CFPB proposed rule imposing a new regulatory regime on prepaid products, including traditional prepaid cards and prepaid accounts. The proposal would impose certain requirements on prepaid products under Regulation E provisions applicable to debit transactions; existing credit card protections found in the Truth in Lending Act and Regulation Z; and implement various consumer protection enhancements addressed by the CARD Act. The proposed rule would also impose a 30-day waiting…

    Discusses CFPB proposed rule imposing a new regulatory regime on prepaid products, including traditional prepaid cards and prepaid accounts. The proposal would impose certain requirements on prepaid products under Regulation E provisions applicable to debit transactions; existing credit card protections found in the Truth in Lending Act and Regulation Z; and implement various consumer protection enhancements addressed by the CARD Act. The proposed rule would also impose a 30-day waiting period before a consumer can be offered credit features associated with a prepaid product; and would establish standardized disclosure requirements.

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  • CFPB Proposes Comprehensive New Regulatory Regime for Prepaid Cards

    Stay Current: A Client Alert from Paul Hastings

    Discusses CFPB proposed rule imposing a new regulatory regime on prepaid products, including traditional prepaid cards and prepaid accounts. The proposal would impose certain requirements on prepaid products under Regulation E provisions applicable to debit transactions; existing credit card protections found in the Truth in Lending Act and Regulation Z; and implement various consumer protection enhancements addressed by the CARD Act. The proposed rule would also impose a 30-day waiting…

    Discusses CFPB proposed rule imposing a new regulatory regime on prepaid products, including traditional prepaid cards and prepaid accounts. The proposal would impose certain requirements on prepaid products under Regulation E provisions applicable to debit transactions; existing credit card protections found in the Truth in Lending Act and Regulation Z; and implement various consumer protection enhancements addressed by the CARD Act. The proposed rule would also impose a 30-day waiting period before a consumer can be offered credit features associated with a prepaid product; and would establish standardized disclosure requirements.

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