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California Rolls Out New Venture Capital Diversity Reporting Requirements

California’s new law, Fair Investment Practices by Venture Capital Companies, will require diversity reporting by venture capital and similar investment firms with a California nexus beginning in 2026. Deadlines are fast...more

Ninth Circuit Hears Oral Argument in Challenge to California Climate Disclosure Laws SB 261 and SB 253; No Ruling Yet

On January 9, 2026, a three-judge panel for the U.S. Court of Appeals for the Ninth Circuit heard oral argument in a challenge to California Senate Bills (SB) 261 and 253 in Chamber of Commerce v. Sanchez, No. 25-5327 (9th...more

OCC Issues Another Crypto-Friendly Interpretive Letter: Permissibility of Riskless Principal Crypto-Assets Transactions

On December 9, 2025, the Office of the Comptroller of the Currency (OCC) issued Interpretive Letter 1188 (IL 1188), confirming that a national bank is permitted, as part of the business of banking, to engage in riskless...more

CARB Releases Proposed Regulations for SB 261 and 253

On December 9, 2025, the California Air Resources Board (CARB) released its proposed regulatory text for the initial regulations implementing Senate Bills (SB) 261 and 253. SB 261 requires covered entities to publish...more

CARB Climate Disclosure Laws Updates: CARB Enforcement Advisory for SB 261 and Docket Opening; Expected Deadline for SB 253

On December 1, 2025, the California Air Resources Board (CARB) provided multiple updates regarding its implementation of Senate Bill (SB) 261 following the U.S. Court of Appeals for the Ninth Circuit’s order staying...more

Ninth Circuit Stays Enforcement of California Climate Disclosure Law SB 261 Pending Appeal

On November 18, 2025, the U.S. Court of Appeals for the Ninth Circuit issued an order enjoining enforcement of California Senate Bill 261 (“SB 261”) pending an appeal filed by the U.S. Chamber of Commerce and other business...more

CA Climate Disclosures – SB 261 – January 1, 2026 Reporting Deadline and CARB “Preliminary List” of Covered Entities

While the January 1, 2026, statutory deadline for reporting under California’s Climate-Related Financial Risk Act (SB 261) is quickly approaching, there is still time for regulated entities to comply with the law. Although...more

Banking and Digital Assets: Key Takeaways from the President’s Working Group Report

On July 30, 2025, the President’s Working Group on Digital Asset Markets (PWG) released “Strengthening American Leadership in Digital Financial Technology,” a comprehensive digital asset report (Report) mandated by President...more

Thorny Laws That ICHRA Vendors Should Consider, Part Three: FinTech Edition

We continue our series on the legal and regulatory challenges facing individual coverage health reimbursement arrangements (ICHRAs); this time, we are focusing on the fintech-related requirements that may apply to ICHRA...more

Is Your Company Prepared for the FTC’s Junk Fees Rule, Effective May 12?

On May 5, 2025, the Federal Trade Commission (FTC or “the Commission”) published FAQs aimed at providing consumers and businesses with information regarding the agency’s Rule on Unfair or Deceptive Fees (the “Junk Fees Rule”...more

SEC Climate Disclosures Rules One Step Closer to the Grave; GHG Emissions Disclosures One Step Closer to Becoming a Multi-State...

The slow death of the Securities and Exchange Commission’s (SEC) climate disclosure rules continued on March 27, 2025, with the SEC Commissioners voting to discontinue the defense of such rules before the Eighth Circuit, Iowa...more

CFPB, FDIC, and OCC Updates: Firings, Appointments, and Potential Consolidation

We previously reported on changes to leadership at the Consumer Financial Protection Bureau (CFPB), the halt of all activities at the CFPB, and the impacts to the financial services industry. The environment continues to...more

New Consumer Financial Protection Bureau Acting Director Expands Freeze to All CFPB Activities; CFPB Office Closes

We previously reported that Treasury Secretary Bessent was named as the acting director of the Consumer Financial Protection Bureau (CFPB), and he subsequently ordered the CFPB staff to halt several activities. However, the...more

FTC Finalizes “Click-to-Cancel” Rule 18 October 2024

The Federal Trade Commission (FTC) has finalized amendments to the Negative Option Rule, now retitled the “Rule Concerning Recurring Subscriptions and Other Negative Option Programs“ (“Rule”), which represents a significant...more

California’s Legislature Pushes Forward with Climate Accountability Bills

After not accepting California Governor Newsom’s proposal to delay implementing California’s Climate Accountability laws by two years, the California legislature passed amendments on August 31, 2024, to California’s 2023...more

Will the End of Chevron Deference Be a Sea Change for Consumer Financial Services Industry?

On June 28, 2024, the Supreme Court decided Loper Bright Enterprises v. Raimondo, overturning its own 40-year-old Chevron v. Natural Resources Defense Council decision. In Chevron, the Supreme Court articulated the so-called...more

Supreme Court Rules That the CFPB Is Constitutionally Funded

On May 16, 2024, the Supreme Court reversed a Fifth Circuit decision which held that the funding for the Consumer Financial Protection Bureau (CFPB) violated the Appropriations Clause. This case was viewed as pivotal to the...more

Legal Decision Expected Today Regarding Implementation of CFPB Rule Reducing Credit Card Late Fees

On March 5, 2024, the Consumer Financial Protection Bureau (CFPB) finalized a rule (“Final Rule”) that would reduce credit card late fees to $8 for large credit card issuers (“Larger Card Issuers”). This rule comes on the...more

CFPB Announces Proposed Rule Regarding Nonsufficient Funds Fees

On Wednesday, January 24, 2024, the Consumer Financial Protection Bureau (CFPB) announced a Proposed Rule aimed at blocking nonsufficient funds (NSF) fees on debit card, ATM, and certain peer-to-peer payment transactions that...more

SEC Voluntarily Stays Final Rule on Climate Disclosures

On April 4, 2024, the U.S. Securities and Exchange Commission (SEC) issued an order staying the Final Rule for the Enhancement and Standardization of Climate-Related Disclosures for Investors (“Final Rule”) that it released...more

SEC Greenlights Bitcoin ETFs: What Happened and What It Portends

On January 10, 2024, the U.S. Securities and Exchange Commission (SEC) approved the launch of several BTC Exchange-Traded Funds (ETFs).[1] The approval order resolves the critical legal and regulatory issues entailed in...more

Tired of Waiting on the SEC, California Adopts Extensive Climate Disclosure Laws

California recently has passed three climate disclosure laws, with yet another still pending. These new laws are aimed at increasing transparency and consistency in climate-related disclosures, including greenhouse gas (GHG)...more

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