The Rise of FringeTech : Regulatory Risks in Earned-Wage Access

By many accounts, the financial technology, or FinTech, sector appears to have developed an innovative solution to assist low-income workers with income shortfalls between standard paydays by displacing fringe financial service providers, namely payday lenders. Earned wage access programs facilitate early transfers of earned-but-unpaid wages to low- income workers through mobile platforms, algorithmic technology, and GPS tracking. To many, earned wage access programs represent a win-win for employees and employers. These programs are believed to be cheaper and safer alternatives to payday loans. Preliminary research also suggests these programs improve labor-retention rates for employers and help reduce financial distress for low-income employees. Consequently, a growing number of employers, including Walmart Inc. and Amazon.com, Inc., have partnered with earned wage access providers to offer these programs as an employee benefit. Employees may also use third-party providers that bypass employers to offer these programs directly through mobile-app stores. In less than a decade, this nascent market has impressively achieved national scale, hundreds of thousands of employer partnerships, millions of users, and billions of dollars in transactions. Yet, notwithstanding and perhaps because of these early successes, these programs also have downsides that have been much less emphasized. In particular, although the gatekeeping role that employers may play when partnering with earned wage access programs has the potential to facilitate improved pricing and service terms in the fringe financial market, such a role also masks significant costs that are not fully disclosed to employees. Additionally, the earned wage access market creates detrimental regulatory blind spots and enables regulatory arbitrage by blurring the lines between once-distinct financial services: money-transmission services and loan services. Earned wage access programs have largely operated with minimal legal constraints because they have generally been characterized as money- transmission services, rather than loan services like payday loans. Building on the FinTech literature, by analogy, this Article argues that this blanket characterization of earned wage access programs is a mistake. Earned wage access programs have varying effects. In the absence of regulatory guardrails, some programs can perpetuate, and in some instances exacerbate, the very risks providers claim to eliminate when displacing short-term creditors like payday lenders. This Article proposes a federal-level regulatory framework based on lending laws that addresses some of these unmitigated risks through the imposition of consumer-protection requirements such as uniform price disclosure, ability-to-repay rules, optional amortization mechanics, mandatory credit reporting, and a right-to-rescind assignment. In doing so, this Article aims to facilitate growth of the earned wage access market’s functional improvements and prevent a mere shift to fringe FinTech, or “FringeTech,” services

A Flexible Alignment Fixture for the Fabrication of Replication Mandrels

NASA uses precision diamond turning technology to fabricate replication mandrels for its X-ray Calibration Facility (XRCF) optics. The XRCF optics are tubular, and the internal surface contains a parabolic profile over the first section and a hyperbolic profile over the last. The optic is fabricated by depositing layers of gold and nickel on to the replication mandrel and then separating it from the mandrel. Since the mandrel serves as a replication form, it must contain the inverse image of the surface. The difficulty in aligning the mandrel comes from the fabrication steps which it undergoes. The mandrel is rough machined and heat treated prior to diamond turning. After diamond turning, silicon rubber separators which are undercut in radius by 3 mm (0.12 in.) are inserted between the two end caps of the mandrel to allow the plating to wrap around the ends (to prevent flaking). The mandrel is then plated with a nickel-phosphor alloy using an electroless nickel process. At this point, the separators are removed and the mandrel is reassembled for the final cut on the DTM. The mandrel is measured for profile and finish, and polished to achieve an acceptable surface finish. Wrapping the plating around the edges helps to prevent flaking, but it also destroys the alignment surfaces between the parts of the mandrel that insure that the axes of the parts are coincident. Several mandrels have been realigned by trial-and-error methods, consuming significant amounts of setup time. When the mandrel studied in this paper was reassembled, multiple efforts resulted in a minimum radial error motion of 100 microns. Since 50 microns of nickel plating was to be removed, and a minimum plating thickness of 25 microns was to remain on the part, the radial error motion had to be reduced to less than 25 microns. The mandrel was therefore not usable in its current state

The human renal lymphatics under normal and pathological conditions

Ishikawa Y, Akasaka Y, Kiguchi H, Akishima-Fukasawa Y, Hasegawa T, Ito K, Kimura-Matsumoto M, Ishiguro S, Morita H, Sato S, Soh S & Ishii T (2006) Histopathology 49, 265–273 The human renal lymphatics under normal and pathological conditions AIMS: The renal lymphatics have not been fully documented in humans. The aim of this study was to clarify the morphology of the human renal lymphatic system under normal and pathological conditions by immunohistochemistry using anti-D2-40 antibody. METHODS AND RESULTS: Normal and pathological renal tissues obtained at autopsy as well as nephrectomy specimens with renal cell carcinoma (RCC) were used. Thin sections were immunostained with antibodies against D2-40 and CD31. In normal kidney, D2-40+ lymphatics were abundant in the interstitium around the interlobar and arcuate arteries/veins but sporadic in those around the glomeruli or between the tubules in the cortex. A few lymphatics contained erythrocytes in their lumina. Lymphatics were seldom present in the medulla. In RCC cases, lymphatics were evident at the tumour margin, whereas CD31+ capillaries were abundant throughout the tumour and lymphatics were increased in the fibrous interstitium around the tumour. Lymphatic invasion by RCC cells was also detectable. D2-40+ lymphatics were evident in other pathological conditions and end-stage kidney had a denser lymphatic distribution than normal kidney. CONCLUSIONS: Lymphatics are abundant around the arteries/veins and are also present in the renal cortex and medulla. D2-40 immunostaining is helpful for investigating the pathophysiological role of renal lymphatics

An Unpublished Act of David II, 1359

This is a transcription, translation and commentary on an overlooked act of David II of Scotland from a 1359 treaty of alliance with France

Distributed Generation: Cleaner, Cheaper, Stronger - Industrial Efficiency in the Changing Utility Landscape

Electricity is illuminating, but its generation, transmission, and distribution have long been opaque. This report looks at how the once static utility industry is becoming a dynamic and transformative opportunity for the nation's economic, environmental, and energy future.An array of technological, competitive, and market forces are changing how the U.S. generates power and the ways that Americans interact with the electric grid. A century-old centralized system is yielding to advanced, distributed-energy generation capabilities -- in which power is produced at or near the place where it is consumed -- that allow the industry to respond to new market opportunities and evolving consumer desires.The report concludes with an evaluation of the impact of key regulatory and legislative policies on the deployment of industrial energy efficiency technologies in order to help federal policymakers effectively encourage adoption of these systems. The Pew Charitable Trusts commissioned ICF International Inc. to model these policies and found that implementation of the U.S. Environmental Protection Agency's Clean Power Plan and an improved federal investment tax credit could result in a 27 percent increase in adoption by 2030

NRG Oncology-Radiation Therapy Oncology Group Study 1014: 1-Year Toxicity Report From a Phase 2 Study of Repeat Breast-Preserving Surgery and 3-Dimensional Conformal Partial-Breast Reirradiation for In-Breast Recurrence.

PURPOSE: To determine the associated toxicity, tolerance, and safety of partial-breast reirradiation. METHODS AND MATERIALS: Eligibility criteria included in-breast recurrence occurring \u3e1 year after whole-breast irradiation, \u3c3 \u3ecm, unifocal, and resected with negative margins. Partial-breast reirradiation was targeted to the surgical cavity plus 1.5 cm; a prescription dose of 45 Gy in 1.5 Gy twice daily for 30 treatments was used. The primary objective was to evaluate the rate of grade ≥3 treatment-related skin, fibrosis, and/or breast pain adverse events (AEs), occurring ≤1 year from re-treatment completion. A rate of ≥13% for these AEs in a cohort of 55 patients was determined to be unacceptable (86% power, 1-sided α = 0.07). RESULTS: Between 2010 and 2013, 65 patients were accrued, and the first 55 eligible and with 1 year follow-up were analyzed. Median age was 68 years. Twenty-two patients had ductal carcinoma in situ, and 33 had invasive disease: 19 ≤1 cm, 13 \u3e1 to ≤2 cm, and 1 \u3e2 cm. All patients were clinically node negative. Systemic therapy was delivered in 51%. All treatment plans underwent quality review for contouring accuracy and dosimetric compliance. All treatment plans scored acceptable for tumor volume contouring and tumor volume dose-volume analysis. Only 4 (7%) scored unacceptable for organs at risk contouring and organs at risk dose-volume analysis. Treatment-related skin, fibrosis, and/or breast pain AEs were recorded as grade 1 in 64% and grade 2 in 7%, with only 1 ( CONCLUSION: Partial-breast reirradiation with 3-dimensional conformal radiation therapy after second lumpectomy for patients experiencing in-breast failures after whole-breast irradiation is safe and feasible, with acceptable treatment quality achieved. Skin, fibrosis, and breast pain toxicity was acceptable, and grade 3 toxicity was rare

The English Crown and the Election of Pope John XXII

This article investigates the involvement of Edward II in the negotiations that led to John XXII's election on 7 August 1316 after a two-year papal vacancy between 1314 and 1316. The main source for this analysis is a dossier of sixteen diplomatic documents, found among the Chancery records in The National Archives in London. The article concludes that Edward II tried to exploit the papal vacancy as a means to re-establish his international profile and seek support abroad in order to face opposition at home, thus ensuring a place for the English Crown within the European political milieu

Accelerated partial breast irradiation: the case for current use

The treatment of early stage breast cancer is evolving from traditional breast conservation techniques, employing conventionally fractionated whole breast irradiation, to techniques in which partial breast irradiation is used in an accelerated fractionation scheme. A growing body of evidence exists, including favorable findings. Additional studies are under way that may ultimately prove equivalence. The logic behind this approach is reviewed, and the currently available data are presented to support the current use of carefully applied partial breast irradiation techniques in appropriately selected and informed patients