Jesse Silverman

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.

@regulatorynerd Congrats @regulatorynerd. MT just entered the premier level of payments knowledge with this addition.

Very excited to deliver the next generation of fiat and stablecoin products with the team at Modern Treasury. Reach out if you need ACH, RTP and stablecoins that actually work. go.moderntreasury.com/4a2p4kd

Another chapter in the unions case against the CFPB has been written District Court ruled that the CFPB’s interpretation (based on the DOJ’s analysis) of the funding mechanism was inaccurate and the CFPB must request funding from the Fed to remain operating (Decision follows)

@JohnDiIorio2 Interesting question that I’ll just punt on, by noting that the drafters of Dodd Frank saw abusiveness as a separate category.

@jbsilverman What could be abusive that isn't covered by deceptive and/or unfair?

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)

The opinion (rather obviously) notes that this is very fact specific and does not preempt state law, nor does it excuse deceptive and unfair practices (what about abusive practices?)

One of the big demarcation lines seems to be with respect to fees. If the fees are voluntary or optional (like expedited funding fees), then it appears to be EWA. If the fees are mandatory, then it appears to be more like credit.

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”

Another interesting study from the NY Fed (in next tweet) on the impacts of state usury caps. And the TLDR is that they’re bad for the poor (available credit contracts without improving delinquencies) and good for the rich (availability of credit expands)

@GametimeCT They missed it for 9 years and couldn’t solve this? Between this and barring the sportswriter from CIAC games for “threats”, whoever is running the CIAC these days should probably be replaced. Quickly too.

CT high school basketball classic canceled in 10th year for being a non-sanctioned CIAC event ift.tt/PnuIiTv #ctbb

@scottew Hope you’re right. In fact, over a long enough time horizon, I’m sure you’re right. But for the near future, those prices seem to be rising with little end in sight. And I suspect the growth in data centers is going to eat a chunk of whatever improvements to production we make

@jbsilverman yep that is a problem, but seems like a short-term one given cost curves of things like solar (and our revived interest in building nuclear)

inevitable, even with gas going below $2 EVs are just better overall

Interesting article on the potential expansion of deposit insurance limits from two very … different … perspectives which, nevertheless, share the same concerns

@regulatorynerd @ModernTreasury Ps: guess it wasn’t OF …

@regulatorynerd @ModernTreasury Congrats! Great hire

1/ I’m excited to announce my next adventure in startup land.  Earlier this month I joined @ModernTreasury.

Very interesting look at impact on banks of Stablecoins. Worth a read (or at least this summary)

@regulatorynerd Why you keeping us all in suspense? OnlyFans pages need publicity

I'm no longer with Trustly. I made coffee pot chicken over on LinkedIn, so am doing the easy screenshot repost here. Am very excited for the new thing, which I started last week. More on that to come . . .