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 ,
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
On April 8, a federal court granted the CFPB’s motion to withdraw from its joint enforcement action against a global money transmitter. The lawsuit, originally filed in April 2022 in partnership with the New York Attorney...more
On April 7, the FCC issued an order staying the effective date of a key provision in its Telephone Consumer Protection Act (TCPA) rules. The provision—originally set to take effect on April 11, 2025—would have required that a...more
On April 4, the California Department of Financial Protection and Innovation (DFPI) issued proposed regulations under the Digital Financial Assets Law (DFAL). The proposal provides clarification on DFAL’s licensing framework...more
4/14/2025
/ California ,
Cryptocurrency ,
Department of Financial Protection and Innovation (DFPI) ,
Digital Assets ,
FinTech ,
Government Agencies ,
Licensing Rules ,
Proposed Rules ,
Regulatory Agenda ,
Regulatory Requirements ,
Rulemaking Process
On March 20, the New York Department of Financial Services (NYDFS) entered into a consent order with a money transmitter, joining a group of state financial regulators acting through a multi-state task force coordinated by...more
4/14/2025
/ Consent Order ,
CSBS ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Money Transmitter ,
New York ,
NYDFS ,
Penalties ,
Regulatory Requirements ,
Settlement ,
State and Local Government ,
State Regulators
On March 28, the Federal Reserve, FDIC, and OCC jointly announced plans to rescind 2023 revisions to the Community Reinvestment Act (CRA) regulations. The agencies stated they would return to the previous regulatory framework...more
On March 28, the CFPB announced that it will not prioritize enforcement or supervision of the remaining provisions of its Payday, Vehicle Title, and Certain High-Cost Installment Loans Regulation, which were set to take...more
On March 28, the FDIC issued updated guidance clarifying the process for FDIC-supervised institutions to engage in crypto-related activities. The guidance rescinds and replaces prior instructions issued in 2022 and makes...more
Utah and Arkansas have enacted new legislation governing earned wage access (EWA) services, establishing state-level registration obligations and consumer protection standards. Both laws clarify that EWA services are not...more
Following President Trump’s March 6 Executive Order establishing a Strategic Bitcoin Reserve and U.S. Digital Asset Stockpile, federal agencies and market participants may begin to grapple with the operational and compliance...more
On February 20, the Virginia General Assembly passed the High-Risk Artificial Intelligence Developer and Deployer Act. If signed into law, Virginia would become the second state, after Colorado, to enact comprehensive...more
3/24/2025
/ Artificial Intelligence ,
Compliance ,
Consumer Protection Laws ,
Enforcement ,
New Legislation ,
Regulatory Agenda ,
Regulatory Requirements ,
Risk Management ,
State Attorneys General ,
State Legislatures ,
Technology Sector
On March 7, the OCC issued Interpretive Letter 1183 and an accompanying statement affirming prior guidance regarding whether national banks and federal savings associations may engage in cryptocurrency-related activities,...more
3/17/2025
/ Banking Sector ,
Blockchain ,
Cryptocurrency ,
Digital Assets ,
Financial Institutions ,
Financial Services Industry ,
Interpretive Letters ,
OCC ,
Payment Systems ,
Regulatory Requirements ,
Risk Management ,
Stablecoins
On March 4, the California DFPI finalized regulations under the Debt Collection Licensing Act (DCLA). The final regulations, which take effect July 1, 2025, clarify key licensing and reporting requirements....more
3/17/2025
/ California ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Protection Laws ,
Debt Collection ,
Department of Financial Protection and Innovation (DFPI) ,
Final Rules ,
New Regulations ,
Regulatory Agenda ,
Regulatory Oversight ,
Regulatory Requirements ,
Reporting Requirements
The CFPB is facing pushback from the U.S. Senate over two final rules issued under the Biden administration: one expanding oversight of nonbank digital payment providers and another limiting the reporting of medical debt....more