On July 10, 2025, the U.S. Senate confirmed Jonathan Gould as Comptroller of the Currency in a 50–45 vote. Gould will serve a five-year term and returns to the OCC, where he previously served as Chief Counsel and Senior...more
On July 1, the CFPB terminated two separate consent orders, one involving a federal credit union and the other involving a national mortgage servicer. Both orders stemmed from 2024 enforcement actions and involved alleged...more
On June 25, the Federal Housing Finance Agency (FHFA) issued a directive ordering Fannie Mae and Freddie Mac to prepare proposals for treating cryptocurrency held on U.S.-regulated exchanges as assets for reserves in...more
On June 23, the Federal Reserve Board announced that reputational risk will no longer be a component of its bank-examination program. The same day, the Board released a revised edition of its Guidelines for Rating Risk...more
6/27/2025
/ Banking Sector ,
Banks ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
OCC ,
Prudential Regulation Authority (PRA) ,
Regulatory Reform ,
Regulatory Requirements ,
Risk Management
On May 14, the OCC entered into a formal agreement with a New York-based bank after determining that the institution is in “troubled condition.” In its findings, the OCC cited alleged unsafe or unsound practices tied to the...more
6/27/2025
/ Banking Sector ,
Banks ,
Consent Order ,
Corrective Actions ,
Enforcement Actions ,
Financial Institutions ,
New York ,
OCC ,
Regulatory Oversight ,
Regulatory Requirements ,
Risk Management ,
Strategic Planning
On June 1, the Illinois General Assembly passed a bill that, if enacted, will delay the effective date of the Interchange Fee Prohibition Act by one year, from July 1, 2025, to July 1, 2026.
The law prohibits financial...more
6/13/2025
/ Banks ,
Credit Cards ,
Financial Institutions ,
Illinois ,
Interchange Fees ,
New Legislation ,
Payment Systems ,
Proposed Legislation ,
Regulatory Reform ,
Regulatory Requirements ,
State and Local Government
On June 9, Acting Comptroller of the Currency Rodney Hood issued a letter rejecting the Conference of State Bank Supervisors’ (CSBS) request that the OCC rescind its 2011 preemption regulations.
The OCC ‘s letter signals...more
6/13/2025
/ Banking Sector ,
Banks ,
Dodd-Frank ,
Financial Institutions ,
Financial Regulatory Reform ,
Government Agencies ,
OCC ,
Preemption ,
Regulatory Agencies ,
Regulatory Oversight ,
Regulatory Requirements ,
State and Local Government
On April 7, the FDIC and the Maryland Office of Financial Regulation terminated two consent orders against a regional bank headquartered in Maryland. The termination concludes joint federal and state enforcement actions that...more
On May 16, Vermont Governor Phil Scott signed into law S. 27, a medical debt relief measure that prohibits the inclusion of medical debt on consumer credit reports and establishes a state-funded initiative to abolish...more
5/30/2025
/ Consumer Financial Protection Bureau (CFPB) ,
Consumer Protection Laws ,
Credit Reports ,
Debt Collection ,
Disclosure Requirements ,
Financial Institutions ,
Healthcare ,
Healthcare Facilities ,
Medical Debt ,
New Legislation ,
Nonprofits ,
Regulatory Reform ,
State and Local Government
On May 21, the U.S. District Court for the Western District of Tennessee granted a joint motion by the CFPB and DOJ to terminate a 2021 redlining settlement with a regional bank, vacating the consent order and dismissing the...more
On May 15, the CFPB issued an amended consent order against an international remittance provider, reducing its civil penalty from $2.025 million to $44,955. The order alleges violations of the Electronic Fund Transfer Act...more
On May 20, federal merger policy took a sharp turn as the FDIC voted to rescind its 2024 merger guidelines, and the U.S. House passed a Congressional Review Act (CRA) resolution to repeal the OCC’s 2024 merger rule....more
On May 20, the U.S. Senate voted 66-32 to move forward with the Guardrails and Enforcement for Neutral Issuers of United States Stablecoins (GENIUS) Act (the “Act”), pushing the stablecoin bill past a major procedural hurdle....more
5/23/2025
/ Banking Sector ,
Cryptocurrency ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Government Agencies ,
Legislative Agendas ,
New Legislation ,
Proposed Legislation ,
Regulatory Requirements ,
Stablecoins
On May 9, the U.S. Department of the Treasury announced that President Trump intends to nominate Jonathan McKernan to serve as the Undersecretary of Domestic Finance. McKernan had been awaiting Senate confirmation to lead the...more
On May 9, President Trump signed a Congressional Review Act resolution repealing the CFPB’s final rule restricting overdraft fees at large financial institutions. The rule, originally finalized under the Biden administration,...more
5/16/2025
/ Banks ,
Biden Administration ,
Congressional Review Act ,
Consumer Financial Protection Bureau (CFPB) ,
Final Rules ,
Financial Institutions ,
Overdraft Fees ,
Popular ,
Regulatory Reform ,
Regulatory Requirements ,
Trump Administration ,
Truth in Lending Act (TILA)
On May 7, the OCC issued Interpretive Letter 1184, reaffirming that national banks and federal savings associations may provide cryptocurrency custody and execution services, including through sub-custodians. The OCC...more
5/16/2025
/ Banks ,
Cryptoassets ,
Cryptocurrency ,
Custody ,
Digital Assets ,
Financial Institutions ,
New Guidance ,
OCC ,
Regulatory Oversight ,
Risk Management ,
Technology
On May 6, Indiana Governor Mike Braun signed House Enrolled Act No. 1125 into law, making Indiana the latest state to enact a statutory framework for regulating earned wage access (EWA) products. The Indiana Earned Wage...more
On May 1, the CFPB filed a joint motion with two financial trade groups to vacate a Biden-era rule barring most medical debt from appearing on consumer credit reports. The motion comes after lender groups filed a lawsuit in...more
On April 15, Judge Mark T. Pittman of the U.S. District Court for the Northern District of Texas entered an Order and Final Judgement vacating the CFPB’s 2024 credit card late fee rule (previously discussed here) for...more
On April 16, the CFPB released an internal memo outlining major shifts in its supervision and enforcement priorities, signaling a retreat from several areas of regulatory activity. The next day, the Bureau issued formal...more
On April 11, North Dakota enacted HB 1127, overhauling its regulatory framework for financial institutions and nonbank financial service providers. The law amends multiple chapters of the North Dakota Century Code and creates...more
On April 23, the CFPB voluntarily dismissed with prejudice its lawsuit, filed in September 2024, against a Pennsylvania-based credit card company that had been accused of unlawfully marketing a high-cost, limited-use...more
In January 2025, the Maryland Office of Financial Regulation (the “OFR”) issued a guidance stating that assignees of residential mortgage loans, including certain passive trusts, were required to hold a Maryland mortgage...more
On April 9, the Federal Reserve Bank of Kansas City published a research briefing examining how video game platforms are reshaping the digital payments landscape. As in-game purchases and platform-based transactions grow in...more
4/21/2025
/ Banking Sector ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Federal Reserve ,
Financial Institutions ,
FinTech ,
Payment Systems ,
Regulatory Requirements ,
Risk Management ,
Technology Sector ,
Video Games
On April 7, the FCC issued an order staying the effective date of a key provision in its Telephone Consumer Protection Act (TCPA) rules. The provision—originally set to take effect on April 11, 2025—would have required that a...more