Consumer Finance Monitor Podcast Episode: A Debate About The Need, If Any, For a Federal Charter for Non-Banks Engaged in the Payments Business
Consumer Finance Monitor Podcast Episode: A Close Look at the Consumer Financial Protection Bureau’s Proposal to Supervise Large Nonbank Providers of Digital Wallets and Payment Apps
In The Cross-Hairs? Protecting Your Company Against Consumer Financial Protection Bureau Investigations and Investors' Mortgage Buyback Claims
The Basel Committee on Banking Supervision has published a comprehensive report analysing the rise of synthetic risk transfer ("SRT") markets, finding that synthetic risk transfer transactions have become a significant source...more
Members of DLA Piper’s Global Fund Finance group recently sponsored and attended the 2026 Fund Finance Association Symposium. A variety of participants in the fund finance market – including institutional banks, private...more
In December 2025, the FCA published its final Policy Statement and guidance (Final Guidance) on the treatment of non-financial misconduct (NFM) under the Code of Conduct (COCON) and the Fit and Proper (FIT) regime, with...more
The CFPB, under former Director Rohit Chopra, regularly engaged in regulatory overreach, the Bureau’s current leadership said in its semi-annual report, covering the period from April 1- September 30, 2024. “As indicated...more
On January 7, the NYDFS finalized a rule amending its banking regulations to implement New York’s state Community Reinvestment Act requirements for certain nonbank mortgage lenders. The rule requires DFS to review how covered...more
The Federal Reserve Board (the Board) has issued a Request for Information and Comment (RFI) on the development of a special purpose Reserve Bank account prototype, being referred to colloquially as a "skinny master account"...more
On 19 December 2025, the Financial Conduct Authority (FCA) published a policy statement (PS25/24) finalising the rules and guidance for the Ancillary Activities Test (AAT) under the Ancillary Activities Exemption (AAE)....more
The Federal Reserve Board has requested public input on establishing a prototype "Payment Account." The account would be an alternative, special-purpose Master Account designed solely to clear and settle an institution's own...more
On December 8, the Oregon Department of Consumer and Business Services entered into a consent order with two affiliated companies resolving allegations of violations of the Oregon Consumer Finance Act arising from a bank...more
On December 16, the Federal Reserve Board issued a Request for Information on a new special‑purpose “Payment Account” prototype, which is essentially a stripped‑down Federal Reserve Bank account designed for institutions...more
The European Banking Authority (EBA), the European Central Bank (ECB), national central banks (NCBs), and national supervisory authorities (NSAs) across the EEA have signed a Memorandum of Understanding (MoU). The MoU aims to...more
In a previous Goodwin alert, “FCA Non-Financial Misconduct Rules: Private Fund Managers, Fintechs, and Other Non-Banks Firmly in Scope” (July 2025), we discussed the consultation paper issued by the UK Financial Conduct...more
The Bank of England (BoE) has launched its second system-wide exploratory scenario (SWES) exercise, this time focused on the private markets ecosystem. It will be run in collaboration with a group of banks and NBFIs active in...more
On December 5, 2025, the Office of the Comptroller of the Currency (“OCC”) and Federal Deposit Insurance Corporation (“FDIC”) rescinded guidance on leveraged lending activities by banks. The rescissions should come as a...more
Banks subject to the Agencies’ jurisdiction will now be expected to manage leveraged lending using general risk management principles for safe and sound lending....more
The Trump Administration is ordering all CFPB examiners to read a “Humility Pledge” to officials at supervised entities before conducting exams. In making the announcement, CFPB officials sharply criticized the Biden...more
The Financial Stability Board (FSB) has published a letter from the FSB's Chair, Andrew Bailey, addressed to G20 leaders. The letter urges G20 leaders to accelerate efforts to modernise financial regulation while safeguarding...more
Leveraged finance has experienced notable shifts in recent years, driven by the rapid expansion of private credit and the continued evolution of the broadly syndicated loan (BSL) market. Once clearly separate in structure,...more
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week. Federal Activities: On...more
The CFPB has formally rescinded its rule creating a registry for nonbank enforcement actions. The rule, proposed during the Biden Administration, would have required certain nonbank entities to register certain covered...more
On October 29, the Consumer Financial Protection Bureau (CFPB or Bureau) officially rescinded its rule requiring nonbank entities to register certain agency and court orders with the Bureau. This decision follows a proposal...more
On October 29, the CFPB published a proposed rule in the Federal Register to withdraw its 2023 proposed rule implementing a registry of form contracts used by covered nonbanks to impose terms and conditions that limit...more
The EU's Anti-Money Laundering ("AML") package includes Regulation (EU) 2024/1620 of the European Parliament and of the Council of 31 May 2024 establishing the Authority for Anti-Money Laundering and Countering the Financing...more
Private credit is emerging as a key reshoring enabler, offering manufacturers faster and more flexible access to capital than traditional syndicated loans—critical for meeting government incentive deadlines and outpacing...more
Congress created a new framework around payment stablecoins but has done more than regulate a digital asset class—it has quietly set in motion a potential transformation of the regulation of core payment systems....more