Steven T. Cummings focuses his practice on the regulation of financial services providers, including virtual currency companies, money transmitters and payment processors. Prior to joining SRZ, Steven served as the Virtual Currency Applications Team Lead with the New York State Department of Financial Services (NYDFS). In this role, he supervised a team of lawyers and examiners in evaluating whether virtual currency companies satisfied NYDFS’s anti-money laundering, cybersecurity and consumer protection requirements. Steven also worked on various policy initiatives, including NYDFS’s notice of BitLicense application procedures, coin listing framework and proposed conditional BitLicense framework.

In addition to his role as Virtual Currency Applications Team Lead, Steven also served as an assistance counsel in the cybersecurity division, where he most recently authored guidance for financial services companies regarding steps they could take to help protect themselves from ransomware attacks.

Publications

“As Federal Agencies Organize, US States Continue to Lead in Regulating Digital Assets,CoinDesk, June 8, 2022

CFPB Supports Broad Assertion of State Enforcement Power,” SRZ Alert, May 27, 2022

CFPB Obtains $10 Million Penalty Against Major Bank Using Expansive UDAAP Authority, SRZ Alert, May 11, 2022

CFPB Invokes 'Dormant' Authority to Conduct Exams of Fintech Companies, SRZ Alert, April 27, 2022

Russian Sanctions Update: FinCEN and NYDFS Issue Guidance, SRZ Alert, April 25, 2022

FDIC Issues Letter on Crypto-Related Activities," SRZ Alert, April 13, 2022

Federal Reserve Releases Report on Central Bank Digital Currency, SRZ Alert, Jan. 25, 2022

CFPB Authorizes Debt Collectors to Use Social Media, Text and Email, SRZ Alert, Dec. 20, 2021

CFPB Updates Electronic Fund Transfers FAQs, SRZ Alert, Dec. 16, 2021

“Federal Agencies Issue Joint Statement on Approach to Crypto-Asset Regulation for Banking Organizations,” SRZ Alert, Dec. 1, 2021

“OCC Outlines System for Banks to Engage in Certain Cryptocurrency Activities Subject to Supervisory Non-Objection,” SRZ Alert, Dec. 1, 2021

“FATF Releases Anticipated Guidance for Virtual Assets and Virtual Asset Service Providers, Survey Results on Cross-Border Payments and Proposed Revisions to Beneficial Ownership Standard,” SRZ Alert, Nov. 30, 2021

“President’s Working Group Issues Interagency Risk Assessment of Stablecoins,” SRZ Alert, Nov. 8, 2021

Securities Enforcement Quarterly, SRZ Publication, October 2021; republished in the Harvard Law School Forum on Corporate Governance, November 2021

“Treasury Issues Reports and Guidance to Assist Industry In Addressing Threats Posed by Certain Virtual Currency Transactions and Ransomware Payments,” SRZ Alert, Oct. 28, 2021