On June 9, Maine Governor Janet Mills signed into law LD558, which prohibits the reporting of medical debt to consumer reporting agencies. The law bars medical creditors, debt collectors, and debt buyers from furnishing...more
On May 23, the Texas Supreme Court issued an opinion holding that in determining whether a commercial loan is usurious under Texas state law, the “actuarial method” must be employed. This requires the applicable amount of...more
On June 13, Judge Katherine Polk Failla of the U.S. District Court for the Southern District of New York entered a stipulated final judgement resolving claims brought by the New York Attorney General against a global money...more
On June 1, the Illinois General Assembly passed a bill that, if enacted, will delay the effective date of the Interchange Fee Prohibition Act by one year, from July 1, 2025, to July 1, 2026.
The law prohibits financial...more
6/13/2025
/ Banks ,
Credit Cards ,
Financial Institutions ,
Illinois ,
Interchange Fees ,
New Legislation ,
Payment Systems ,
Proposed Legislation ,
Regulatory Reform ,
Regulatory Requirements ,
State and Local Government
On June 9, Acting Comptroller of the Currency Rodney Hood issued a letter rejecting the Conference of State Bank Supervisors’ (CSBS) request that the OCC rescind its 2011 preemption regulations.
The OCC ‘s letter signals...more
6/13/2025
/ Banking Sector ,
Banks ,
Dodd-Frank ,
Financial Institutions ,
Financial Regulatory Reform ,
Government Agencies ,
OCC ,
Preemption ,
Regulatory Agencies ,
Regulatory Oversight ,
Regulatory Requirements ,
State and Local Government
Louisiana and Connecticut recently passed legislation establishing regulatory frameworks for earned wage access (EWA) providers.
Connecticut’s SB 5140 passed the legislature on June 4 and awaits Governor Ned Lamont’s...more
6/13/2025
/ Consumer Lenders ,
Consumer Protection Laws ,
Disclosure Requirements ,
Earned Wage Access ,
Fees ,
Financial Services Industry ,
Loans ,
New Legislation ,
Regulatory Requirements ,
State and Local Government ,
State Legislatures
On May 28, Nevada Governor Joe Lombardo approved SB 437, creating a new framework for internet-based consumer lenders that lend to Nevada residents. The law defines an “Internet consumer lender” as any entity that exclusively...more
Amendments to California’s Automatic Renewal Law (ARL) will take effect on July 1, 2025. Enacted in September 2024 through Assembly Bill No. 2863, the amendments expand disclosure, consent, and cancellation obligations for...more
On May 27, the CFPB filed a notice of dismissal with prejudice in its lawsuit against a lease-to-own fintech provider. The lawsuit, filed in July 2023, alleged that the company’s rental-purchase agreements violated several...more
On May 23, the CFPB notified a Kentucky federal court that it now considers its own 2023 open banking rule “unlawful” and plans to set the rule aside. The Bureau announced its intent to seek summary judgement against the...more
On May 20, the U.S. Senate voted 66-32 to move forward with the Guardrails and Enforcement for Neutral Issuers of United States Stablecoins (GENIUS) Act (the “Act”), pushing the stablecoin bill past a major procedural hurdle....more
5/23/2025
/ Banking Sector ,
Cryptocurrency ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Government Agencies ,
Legislative Agendas ,
New Legislation ,
Proposed Legislation ,
Regulatory Requirements ,
Stablecoins
On May 12, the CFPB formally withdrew nearly 70 guidance materials—including policy statements, advisory opinions, circulars, and interpretive rules—through a Federal Register notice issued by Acting Director Russell...more
5/16/2025
/ Advisory Opinions ,
Buy Now Pay Later (BNPL) ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Earned Wage Access ,
Federal Register ,
Financial Services Industry ,
Regulatory Authority ,
Regulatory Reform ,
Regulatory Requirements ,
UDAAP ,
Unfair or Deceptive Trade Practices
On May 9, President Trump signed a Congressional Review Act resolution repealing the CFPB’s final rule restricting overdraft fees at large financial institutions. The rule, originally finalized under the Biden administration,...more
5/16/2025
/ Banks ,
Biden Administration ,
Congressional Review Act ,
Consumer Financial Protection Bureau (CFPB) ,
Final Rules ,
Financial Institutions ,
Overdraft Fees ,
Popular ,
Regulatory Reform ,
Regulatory Requirements ,
Trump Administration ,
Truth in Lending Act (TILA)
On May 6, Indiana Governor Mike Braun signed House Enrolled Act No. 1125 into law, making Indiana the latest state to enact a statutory framework for regulating earned wage access (EWA) products. The Indiana Earned Wage...more
On April 29, Acting Comptroller of the Currency Rodney Hood delivered pre-recorded remarks at the National Fair Housing Alliance’s Responsible AI Symposium. In his speech, Hood reiterated the OCC’s commitment to deploying AI...more
5/9/2025
/ Algorithms ,
Artificial Intelligence ,
Banking Sector ,
Diversity and Inclusion Standards (D&I) ,
Financial Services Industry ,
FinTech ,
OCC ,
Popular ,
Regulatory Oversight ,
Regulatory Requirements ,
Risk Management ,
Technology
On April 16, the Colorado General Assembly enacted House Bill 25-1201, replacing the state’s prior money transmitter law with the Money Transmission Modernization Act (the “Act”). Modeled on the multistate framework developed...more
On April 15, Judge Mark T. Pittman of the U.S. District Court for the Northern District of Texas entered an Order and Final Judgement vacating the CFPB’s 2024 credit card late fee rule (previously discussed here) for...more
On April 30, the CFPB announced it will deprioritize enforcement and supervision of its small business lending data collection rule for institutions not covered by the stay issued by the U.S. Court of Appeals for the Fifth...more
On April 22, the Fourth Circuit declined to reconsider a panel ruling that found a credit union could not be held liable for a scam in which fraudsters diverted over $560,000 from a metal fabricator through unauthorized ACH...more
5/1/2025
/ Anti-Money Laundering ,
Appeals ,
Banking Sector ,
Banks ,
Consumer Protection Laws ,
Credit Unions ,
Financial Crimes ,
Fraud ,
Know Your Customers ,
Litigation Strategies ,
NACHA ,
Payment Systems ,
Regulation E ,
Regulatory Requirements
On April 11, North Dakota enacted HB 1127, overhauling its regulatory framework for financial institutions and nonbank financial service providers. The law amends multiple chapters of the North Dakota Century Code and creates...more
On April 11, the CFPB filed a joint motion in the U.S. District Court for the District of Columbia indicating its intent to revoke an advisory opinion on medical debt collection. The Bureau requested a stay of litigation...more
In January 2025, the Maryland Office of Financial Regulation (the “OFR”) issued a guidance stating that assignees of residential mortgage loans, including certain passive trusts, were required to hold a Maryland mortgage...more
On April 9, the Federal Reserve Bank of Kansas City published a research briefing examining how video game platforms are reshaping the digital payments landscape. As in-game purchases and platform-based transactions grow in...more
4/21/2025
/ Banking Sector ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Federal Reserve ,
Financial Institutions ,
FinTech ,
Payment Systems ,
Regulatory Requirements ,
Risk Management ,
Technology Sector ,
Video Games
On April 4, the Securities and Exchange Commission’s (SEC) Division of Corporation Finance issued a statement clarifying that reserve-backed U.S. dollar stablecoins are not securities, at least under current law and...more
4/21/2025
/ Cryptocurrency ,
Digital Assets ,
Financial Regulatory Reform ,
FinTech ,
New Guidance ,
Proposed Legislation ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Stablecoins ,
Technology Sector
On April 11, the CFPB announced that it will not prioritize enforcement or supervision against nonbank financial companies that miss registration deadlines under its Repeat Offender Registry. The Bureau also stated that it is...more