On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more
7/8/2025
/ Bank Secrecy Act ,
Banks ,
BSA/AML ,
Customer Identification Program (CIP) ,
Data Collection ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Money Services Business ,
New Regulations ,
Patriot Act ,
Regulatory Reform ,
Social Security Numbers ,
Taxpayer Identification Number ,
Third-Party ,
U.S. Treasury
The Federal Trade Commission (FTC) recently settled an enforcement action with Paddle.com, a U.K.-based payments company, and its U.S. subsidiary (“Paddle”). The settlement resolves claims against Paddle for violation of the...more
7/8/2025
/ Anti-Money Laundering ,
Consumer Protection Laws ,
Digital Marketplace ,
Due Diligence ,
E-Commerce ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
FinTech ,
Fraud ,
Money Laundering ,
Payment Systems ,
Settlement ,
Telemarketing
The financial services industry generally, and data aggregators specifically, have watched intently as the Trump administration has altered the course of the Consumer Financial Protection Bureau (CFPB or “Bureau”), in an...more
6/13/2025
/ Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Data Privacy ,
Data Protection ,
Dodd-Frank ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
Open Banking ,
Popular ,
Regulatory Authority ,
Regulatory Reform ,
Regulatory Requirements ,
Rulemaking Process ,
Vacated
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
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
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
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
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
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
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
3/21/2025
/ Bank Secrecy Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement Actions ,
FDIC ,
Federal Reserve ,
Financial Regulatory Reform ,
FinTech ,
Military Lending Act ,
OCC ,
Regulatory Agenda ,
Stablecoins
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
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
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
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
2/24/2025
/ Artificial Intelligence ,
Compliance ,
Credit ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Fraud ,
Investment Management ,
Machine Learning ,
Regulatory Requirements ,
Risk Management
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
2/21/2025
/ Congressional Review Act ,
Consumer Financial Protection Bureau (CFPB) ,
CRA ,
Executive Orders ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Regulation Z ,
Regulatory Reform ,
Stablecoins ,
Trump Administration
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
2/14/2025
/ CFTC ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Enforcement Actions ,
Federal Funding ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
OMB ,
Regulatory Agenda
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
2/7/2025
/ Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
Government Efficiency ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Trump Administration
The 119th Congress is underway, and Republicans control both chambers. With President Trump in the White House, both the House and the Senate will focus more of their oversight on the private sector. Continuing a trend over...more
2/5/2025
/ Artificial Intelligence ,
Banking Sector ,
China ,
Congressional Investigations & Hearings ,
Corporate Counsel ,
Critical Infrastructure Sectors ,
Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
Data Privacy ,
Data Protection ,
Data Security ,
Diversity and Inclusion Standards (D&I) ,
Environmental Social & Governance (ESG) ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
Pharmacy Benefit Manager (PBM) ,
Regulatory Agenda ,
Technology Sector
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
2/3/2025
/ Artificial Intelligence ,
Central Bank Digital Currency (CBDCs) ,
Cryptocurrency ,
Digital Assets ,
Executive Orders ,
Financial Regulatory Reform ,
FinTech ,
OMB ,
Regulatory Freeze ,
Secretary of the Treasury ,
Securities and Exchange Commission (SEC) ,
Senate Confirmation Hearings ,
U.S. Treasury
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
1/27/2025
/ Artificial Intelligence ,
CFTC ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Digital Assets ,
Executive Orders ,
FDIC ,
Financial Services Industry ,
Hiring Freeze ,
Regulatory Freeze ,
Regulatory Reform ,
Rescission ,
Securities and Exchange Commission (SEC) ,
Trump Administration
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
1/24/2025
/ Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Cryptocurrency ,
Digital Assets ,
Electronic Fund Transfer Act ,
FinCEN ,
FinTech ,
Proposed Rules ,
Regulation E ,
Rewards Programs ,
Stablecoins ,
Video Games ,
Virtual Currency
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
1/15/2025
/ Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Data Collection ,
Data Privacy ,
Dodd-Frank ,
Final Rules ,
Financial Regulatory Reform ,
Open Banking ,
Pay-To-Play ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management
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
1/8/2025
/ Administrative Procedure Act ,
Compliance ,
Congressional Review Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Disclosure Requirements ,
Fees ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
Overdraft Fees ,
Popular ,
Regulation Z ,
Truth in Lending Act (TILA)
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
12/12/2024
/ Congressional Review Act ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Digital Wallets ,
EFTA ,
Electronic Fund Transfer Act ,
Electronic Payment Transactions ,
Final Rules ,
Financial Services Industry ,
Money Transfer
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