Kara A. Kuchar concentrates her practice on the regulation of financial services providers, and specifically, the regulation of money services businesses, payment processors, virtual currency companies and fintech companies. Kara represents and advises leading money transmitters, payment processors and private equity firms in transactional and regulatory matters associated with payments products and services, including remittance transfers, prepaid access, and internet- and mobile-based payment products and services. She has advised a number of non-bank financial service providers regarding compliance with Consumer Financial Protection Bureau regulations and guidance, including the establishment and enhancement of compliance management systems, implementing remittance rule programs, and strengthening policies and procedures to prohibit unfair, deceptive, or abusive acts or practices. She recently served as regulatory counsel to Western Union in its pending sale of its Speedpay bill payments business; Noventis Inc., a licensed money transmitter and provider of payment solutions, in its acquisition by WEX Inc., a provider of payment processing and information services; Small World Financial Services Group Ltd., a leading international omni-channel payment service provider, and Equistone Partners, a private equity fund, in connection with Equistone’s controlling investment in Small World and its U.S. licensed money transmitter, Choice Money Transfer Inc.; and Securus Technologies Inc. and Platinum Equity, a private equity fund, in connection with its acquisition of Securus and its U.S. licensed money transmitter, JPay Inc., a market-leading technology company that introduced electronic payments and other services to the corrections space. She also acted as regulatory counsel to Trans-Fast Remittance LLC, a leading global payments company, and Apis Growth Fund I, a private equity fund, in connection with the fund’s investment of primary capital into the company; H.I.G. Capital, a private equity fund, in connection with its acquisition of the Keefe Group and its licensed money transmitter, Keefe Commissary Network LLC; Fleetcor Technologies Inc., a leading global provider of commercial payment solutions, and Cambridge Global Payments, a leading B2B international payments provider, in connection with Fleetcor’s acquisition of Cambridge; Travelex Group with its acquisition by a consortium led by the owner of UAE Exchange, a leading global money transfer and foreign exchange provider, and Centurion Investments, an Abu Dhabi-based private equity firm; and Western Union in its acquisitions of Custom House and Travelex Global Business Payments.

Kara is also an author and public speaker on a variety of topics of interest to the payments and fintech industry. She spoke on “Ensuring Compliance with the Increasingly Aggressive State Regulatory and Enforcement Framework Governing Emerging Payment Systems” at the ACI 12th National Forum on Emerging Payment Systems and on “Prepaid Access” at the Money Transmitter Regulators Association Annual Conference & Examiners’ School. Her recent publications include co-authoring “OCC Issues Draft Guidance and Requirements for Fintech Charter Applications” in Bloomberg BNA – Banking Report

Publications

CFPB Issues Request for Information Regarding Potential Changes to Remittance Rule,” SRZ Alert, May 1, 2019 (co-author)

“CFPB Proposes Revisions to Its Policy on No-Action Letters and Creation of New Product Sandbox to Spur Fintech Innovation,” SRZ Alert, Dec. 14, 2018 (co-author)

“OCC Issues Draft Guidance and Requirements for Fintech Charter Applications,” SRZ Alert, March 17, 2017 (co-author); republished in Bloomberg BNA – Banking Report, April 17, 2017

“Virtual Currency Regulation: ‘BitLicense’ Re-Proposed by NYDFS,” SRZ Alert, Feb. 6, 2015 (co-author)

“CFPB Issues Proposed Rule to Provide Additional Federal Consumer Protections for Prepaid Products,” SRZ Alert, Nov. 18, 2014 (co-author)

“CFPB Issues Larger Participants Rule for International Money Transfer Market,” SRZ Alert, Sept. 17, 2014 (co-author)

“Virtual Currency Regulation: Analysis of New York’s Proposal,” Westlaw Journal —Computer & Internet, Sept. 11, 2014 (co-author)

“CFPB Extends Temporary Remittance Rule Exception for Depository Institutions to 2020 and Issues Clarifications and Technical Corrections,” SRZ Alert, Aug. 26, 2014 (co-author)

“Virtual Currency Regulation: Summary and Analysis of the New York State Department of Financial Services Proposal,” SRZ Alert, Aug. 15, 2014 (co-author)

“CFPB Updates Remittance Rule Compliance Guide and Issues Clarifying Amendment and Technical Correction,” SRZ Alert, Aug. 13, 2013 (co-author)

“What Your Prepaid Business Needs to Know about the Dodd-Frank Remittance Transfer Provisions: CFPB Issues Final Rule and Concurrent Notice of Proposed Rulemaking on Safe Harbors,” Paybefore, Feb. 28, 2012 (co-author)

“Consumer Financial Protection Bureau Issues Final Rule and Concurrent Notice of Proposed Rulemaking to Implement the Dodd-Frank Act Remittance Transfer Provisions,” SRZ Alert, Jan. 27, 2012 (co-author)

“Federal Reserve Board Announces TALF Eligibility for Legacy CMBS, Revises Terms & Conditions and FAQ Documents, SRZ Alert, May 22, 2009

“U.S. Treasury Announces Public-Private Investment Program,” SRZ Alert, March 25, 2009

“TALF Program Increased to $1 Trillion and to Provide Financing for Commercial Mortgage-Backed Securities; New Program to Finance Purchases of Illiquid Assets, SRZ Alert, Feb. 11, 2009

”Financing Available for Investors in Asset-Backed Securities from the Federal Reserve Bank of New York Under the TALF Program,” SRZ Alert, Feb. 9, 2009

“Schools May Be Required to Comply with FTC Rules Aimed at Preventing Identity Theft,” SRZ Alert, Jan. 15, 2009

”Banking Agencies Adopt Rules to Protect Credit Card Customers and Federal Reserve Adopts Further Protections by Amending Regulations Z and DD,” SRZ Alert, Dec. 23, 2008

“Summary of the U.S. Treasury Department’s ‘Blueprint For A Modernized Financial Regulatory Structure’,” SRZ Alert, April 3, 2008

Speaking Engagements

“State Activity Round-Up: What Has Changed in the Last Year in State Money Transmitter Licensing Requirements, and the Latest Regulatory Strides to Streamline Multistate Licensing, Examination and Supervision,” ACI FinTech & Emerging Payment Systems Conference, New York, April 2019

Payment Processing – A Deep Dive,” Money Transmitter Regulators Association 2017 Annual Conference & Examiners’ School, Savannah, Ga., September 2017

“Ensuring Compliance with the Increasingly Aggressive State Regulatory and Enforcement Framework Governing Emerging Payment Systems: Bit Licenses, New Issues Relating to State Money Transmitter Licenses (Including the Examination Process), Payment Processing, and Other Considerations,” ACI 12th National Forum on Emerging Payment Systems, San Francisco, July 2016 

“Dodd-Frank Remittance Rule Requirements for Consumer Remittances Originating from the U.S. to Abroad,” ACI Advanced Legal, Regulatory and Compliance Forum on Cross-Border Global Payments & Technologies, New York, November 2015

“Prepaid Access,” Money Transmitter Regulators Association 2015 Annual Conference & Examiners’ School, Kansas City, Mo., October 2015

“Cross-Border Remittances: Dodd-Frank Section 1073, the CFPB and the Emerging Regulatory Paradigm,” ACI 2nd Advanced Forum on International & Cross-Border Payments, San Francisco, June 2013

“What’s Happening on the State Level?,” IIR 8th Annual Prepaid Expo, Orlando, March 2013

“Cross-Border Remittances: Dodd-Frank Section 1073, the Emerging Regulatory Paradigm, and Their Impact on Remittances,” ACI Advanced Forum on International & Cross-Border Payments, New York, November 2012

“Post-Conference Workshop: Prepaid Anti-Fraud and your Program. Leveraging the Power of Actively Collaborating as an Industry and Working with Law Enforcement,” Network Branded Prepaid Card Association The Power of Prepaid, Washington, D.C., June 2012

“Emerging Payment Systems: Legal, Regulatory and Compliance Considerations,” IIR 7th Annual Prepaid Expo, Las Vegas, March 2012

“Legislative and Regulatory Updates Affecting Payments Companies,” Fidelity National Information Services Network Payments Executives Council Forum, Miami, March 2012