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NYDFS Joins Multistate Action Against Money Transmitter for Financial and Licensing Violations

On March 20, the New York Department of Financial Services (NYDFS) entered into a consent order with a money transmitter, joining a group of state financial regulators acting through a multi-state task force coordinated by...more

Federal Regulators Signal Reversal on 2023 CRA Modernization Rule

On March 28, the Federal Reserve, FDIC, and OCC jointly announced plans to rescind 2023 revisions to the Community Reinvestment Act (CRA) regulations. The agencies stated they would return to the previous regulatory framework...more

FDIC Updates Crypto Guidance, Removes Pre-Approval Requirement for Banks

On March 28, the FDIC issued updated guidance clarifying the process for FDIC-supervised institutions to engage in crypto-related activities. The guidance rescinds and replaces prior instructions issued in 2022 and makes...more

CFPB Seeks to Reopen Small Business Lending Rule Under Section 1071

On April 3, the CFPB informed a Florida federal district court that it plans to initiate new rulemaking to revise its small business lending data collection rule under Section 1071 of the Dodd-Frank Act. The Bureau agreed to...more

FDIC Aims to Eliminate Reputational Risk from Supervision

On March 24, acting FDIC Chairman Travis Hill informed Congress that the agency is preparing to eliminate the use of “reputation risk” as a basis for supervisory criticism. In a letter to Rep. Dan Meuser (R-Pa.), Hill...more

OCC Eliminates “Reputational Risk” Category from Bank Supervision Criteria 

On March 20, the OCC announced that it will no longer treat reputation risk as a standalone category in its supervision of national banks and federal savings associations. The decision marks a dramatic shift in the agency’s...more

FTC Signals Strong Stance on Civil Investigation Demands

In a March 10 blog post, the new Director of the FTC’s Bureau of Consumer Protection (BCP) reaffirmed the agency’s commitment to enforcing consumer protection laws through Civil Investigation Demands (CIDs)....more

OCC Clarifies Banks’ Role in Cryptocurrency Activities

On March 7, the OCC issued Interpretive Letter 1183 and an accompanying statement affirming prior guidance regarding whether national banks and federal savings associations may engage in cryptocurrency-related activities,...more

CFPB Drops Two More Major Lawsuits 

The CFPB has recently dismissed two more enforcement actions—one against a major credit reporting agency and another against a lease-to-own financing provider. Both lawsuits involved allegations of abusive, unfair, and...more

CFPB Continues Lawsuit Over Alleged Military Lending Act Violations

On March 1, and despite recent policy shifts under the new administration, the CFPB sent a letter to the judge overseeing its lawsuit against a fintech lender in the United States District Court for the Southern District of...more

FDIC Withdraws Proposed Rule on Brokered Deposits

On March 3, the FDIC announced the withdrawal of its proposed rule on brokered deposits, citing concerns regarding potential disruptions to the financial sector. This move follows significant pushback from industry...more

Maryland OFR Responds to Market Concerns Over Licensing Requirements for Mortgage and Installment Loan Assignees

On February 18, the Maryland Office of Financial Regulation (OFR) issued an alert to address industry concerns regarding its January guidance on licensing requirements for assignees of residential mortgage and installment...more

FDIC Withdraws Support for Colorado’s Opt-Out Law Before Tenth Circuit

On February 26, the FDIC withdrew its amicus brief in the 10th Circuit Court of Appeals challenging Colorado’s 2023 opt-out law which aimed to restricting higher-cost online lending. The FDIC’s decision follows a shift in the...more

Federal Court Pauses Open Banking Rule Litigation

On February 25, a federal judge in the United District Court for the Eastern District of Kentucky approved a joint motion between the CFPB and banking trade groups to pause litigation over the agency’s 1033 open banking rule....more

New CFPB Director Testifies on Agency Leadership and Enforcement Approach

On February 27, new CFPB Director Jonathan McKernan testified before the Senate Banking Committee, emphasizing his commitment to enforcing the law while operating within the confines of the law. His testimony focused on his...more

Second Circuit Upholds Reverse Redlining Verdict Against Mortgage Lender

On February 14, a divided Second Circuit panel upheld a 2016 jury verdict which found that a mortgage lender violated, among other laws, the Equal Credit Opportunity Act (“ECOA”) by engaging in “reverse redlining” when it...more

California Governor Appoints New DFPI Commissioner

On February 7, California Governor Gavin Newsom announced the appointment of Khalil “KC” Mohseni as the new Commissioner of the California Department of Financial Protection and Innovation (DFPI). Mohseni has been serving as...more

CFPB Signals Shift in Position on Section 1071 Compliance Pause

This week, the CFPB filed an emergency notice in the Fifth Circuit Court of Appeals, indicating that it no longer opposes a pause in compliance with its Section 1071 small business data-collection rule. This marks a...more

Treasury Secretary Scott Bessent Appointed as Acting CFPB Director

On January 31, 2025, the CFPB announced President Donal Trump had appointed Scott Bessent as Acting Director of the CFPB. In a brief statement, Bessent expressed his commitment to advancing the administration’s agenda to...more

New York Proposes Limits on Overdraft and NSF Fees

On January 23, 2025 the New York Department of Financial Services (NYDFS) announced proposed regulations to curb overdraft fees and insufficient funds fees charged by banks in New York. The proposed rules aim to protect...more

Maryland Expands Licensing Requirements for Mortgage Loan Assignees

On January 10, 2025, the Maryland Office of Financial Regulation (OFR) issued guidance significantly expanding licensing requirements for assignees of residential mortgage loans in Maryland. The guidance stems from an April...more

Trump Administration Issues Regulatory Freeze

On January 20, President Trump issued a memorandum instituting a regulatory freeze pending review. This action, a common practice for new administrations, directs federal agencies to halt any new rulemaking until agency heads...more

New FDIC Chairman Outlines Agency’s New Priorities

The FDIC will shift its focus and priorities under the leadership of its new Acting Chairman, Travis Hill. In a statement released on January 20, 2025, Chairman Hill signaled a potential departure from some of the initiatives...more

Trade Group Calls for Clarity on Ohio Fintech Guidance

On January 14, 2025, the American Fintech Council (AFC) submitted a letter to the Ohio Department of Financial Institutions, urging it to re-examine its recent guidance on responsible bank partnerships and provide more...more

CFPB Publishes Supervisory Highlights Focused on Deposits, Small-Dollar Lending, BNPL, and Paycheck Advance Products

During the week of January 6, the CFPB released a “second” Winter 2024 Supervisory Highlights, focused on the agency’s most recent findings in deposits, small dollar lending, buy now, pay later (BNPL), paycheck advance...more

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