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OCC Proposed Rule Implementing the GENIUS Act: A Summary and Analysis

On February 25, 2026, the Office of the Comptroller of the Currency (OCC) released a much anticipated notice of proposed rulemaking (“Proposal”) to implement the Guiding and Establishing National Innovation for U.S....more

California DFPI Seeks Comment on Potential Registration and Supervision of Consumer Reporting Agencies

The California Department of Financial Protection and Innovation (DFPI) is sharpening its focus on the credit reporting ecosystem. On January 12, 2026, the DFPI issued a second invitation for public comment, seeking input on...more

California’s Mandatory Diversity Reporting for VC Fund Managers Starts March 1, 2026

California’s Department of Financial Protection and Innovation (“DFPI”) has recently taken concrete steps toward implementing S.B. 164, the Fair Investment Practices by Venture Capital Companies Law (the “California Diversity...more

AI Trends For 2026 - AI and Algorithmic Bias in Financial Services

With the exponential growth of AI technologies, financial institutions must address algorithmic bias head on, as it is one of the most significant emerging issues in certain core activities, including credit underwriting,...more

Key Takeaways from the National Association of Attorneys General 2025 Capital Forum

Beginning on December 8, 2025, the National Association of Attorneys General (NAAG) held its three‑day Capital Forum in Washington, D.C. Throughout the Forum, Attorneys General (AGs), their senior staff, federal officials,...more

CFPB Reestablishes Position That Certain Earned Wage Access Programs Are Not “Credit”

On December 23, 2025, the Consumer Financial Protection Bureau (CFPB or “Bureau”) published an advisory opinion (the “2025 EWA Advisory Opinion”) concluding that certain earned wage access (EWA) programs do not constitute...more

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