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FinReg Currents - Week 14

Each week of the first 100 days of the new Trump administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more

CFPB Reverses Course, Withdrawing “Unprecedented” EFTA Interpretation

Following a brief pause under new leadership, the Consumer Financial Protection Bureau (CFPB) has resumed activities, albeit significantly in retreat from the positions taken by the prior administration. In a case involving...more

FinReg Currents - Week 13

Each week of the first 100 days of the new Trump administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more

FinReg Currents - Week 12

Each week of the first 100 days of the new Trump administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more

FinReg Currents - Week 11

On April 1, 2025, the House Financial Services Committee issued a press release regarding a number of Committee requests to various federal agencies for rescission, modification, or re-proposal of specific Biden...more

FinReg Currents - Week 10

On March 26, 2025, the House Financial Services Committee Subcommittee on Financial Institutions held a hearing, entitled “A New Era for the CFPB: Balancing Power and Reprioritizing Consumer Protections.”...more

FinReg Currents - Week 9

On March 14, 2025, a judge in the U.S. District Court for the District of Maryland declined to grant a temporary injunction to the City of Baltimore and the Economic Action Maryland Fund. The plaintiffs had requested an...more

Navigating Changes in the First 100 Days of the Second Trump Administration

Each week of the first 100 days of the new Trump administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more

FinReg Currents - Week 7

Each week of the first 100 days of the new Trump administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more

FinReg Currents - Week 6

On February 20, 2025, House Majority Leader Steve Scalise (R-La.) issued a list of priority regulatory targets for nullification under the CRA “in the coming weeks.” Included on the list is the CFPB’s December 10, 2024 final...more

AI Trends for 2025 - AI and Financial Services: Balancing Innovation with Regulatory Compliance

As the adoption of artificial intelligence (AI) continues to expand, the financial services industry is leveraging this technology in many ways. AI’s application in credit decision making has become increasingly prominent,...more

FinReg Currents - Week 5

On February 18, 2025, President Trump signed an Executive Order designed to reduce the power of federal independent agencies by bringing them under the purview of the White House. The Executive Order provides that it applies...more

FinReg Currents - Week 4

On February 7, 2025, newly confirmed Office of Management and Budget (OMB) director Russell Vought replaced Treasury Secretary Scott Bessent as acting director of the CFPB....more

FinReg Currents - Week 3

Each week of the first 100 days of the new Trump Administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more

FinReg Currents - Week 2

Each week of the first 100 days of the new Trump Administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more

FinReg Currents - Week 1

On January 20, 2025, President Trump issued a Regulatory Freeze Pending Review (“Regulatory Freeze”) that applies to all executive departments and agencies. The Regulatory Freeze prohibits the proposal or issuance of any rule...more

Not Just Fun and Games? CFPB Seeks Comments on Proposed Interpretive Rule to Place New Forms of Digital Payments, Including...

On January 15, 2025, days before the start of the Trump administration, the Consumer Financial Protection Bureau (CFPB) published a proposed interpretive rule (Proposed Rule) seeking public comment on how the Electronic Fund...more

Open Banking Update: CFPB Recognizes First Open Banking Standard-Setting Body

On January 8, 2025, the Consumer Financial Protection Bureau (CFPB) issued a decision and order approving the application of Financial Data Exchange, Inc. (FDX) for recognition as a standard-setting body (SSB) under the...more

Leaning In: The CFPB Publishes Rule on Fees for Overdraft Services

On December 30, 2024, the Consumer Financial Protection Bureau (CFPB) published a final rule that may dramatically change the way that certain large financial institutions offer overdraft services to consumers. Under the...more

CFPB Asserts Authority to Supervise Large Digital Wallet and Payment App Providers

On December 10, 2024, the Consumer Financial Protection Bureau (CFPB) published a final rule (“Final Rule”) to supervise large providers of digital wallets and payment apps. Specifically, the Final Rule, entitled Defining...more

FDIC Proposes to Walk Back Key Aspects of the Brokered Deposits Rule

On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) issued a proposed rule that would unwind and considerably revise parts of the FDIC’s 2020 final rule governing brokered deposits (the “Proposed Rule”). The...more

FDIC Issues Proposal to Improve Bank Recordkeeping of Fintech Custodial Accounts

On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) issued a proposed rule (the “Proposed Rule”) intended to strengthen recordkeeping for banks that partner with third-party, non-bank companies to accept...more

Banking Agencies Address Banking Arrangements with Third Parties to Provide Deposit Products and Services

On July 25, 2024, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint statement to banks regarding risks...more

Earned Wage Access Products would be “Credit” under CFPB Proposed Interpretive Rule

On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued a proposed interpretive rule on earned wage access (EWA) products (“Proposed Interpretive Rule”) that, if finalized, would clarify that EWA products are...more

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