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FinCEN Issues GTO Imposing New Obligations on Southwest Border MSBs

On March 14, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) in the Federal Register that will impose new obligations on many money services...more

With the Preliminary Injunction of the Corporate Transparency Act Stayed, FinCEN Extends Deadlines for Compliance

The Fifth Circuit Court of Appeals has stayed the preliminary injunction issued on December 3, 2024, in the Texas Top Cop Shop case by a U.S. District Court. As a result, the original beneficial ownership reporting...more

Bank-Fintech Partnerships and Fair Lending: Top Areas at Risk for Government Scrutiny

The Federal Deposit Insurance Corporation (FDIC) recently published a consent order issued against Cross River Bank that alleged the bank’s fair lending program’s noncompliance and weaknesses in its oversight of fintech...more

New York Department of Financial Services Rule Will Require Banks to Collect Demographic Data with Commercial Credit Applications

Lenders will soon be required to collect detailed demographic and financial data on commercial credit applicants and report this data to regulators. The NYDFS issued a proposed rule that will require New York banks to...more

NYDFS Continues Series of Fair Lending Enforcement Actions against New York State-Chartered Banks

NYDFS is closely evaluating fair lending compliance at the institutions it regulates, and bringing enforcement actions based on statistical analyses of lenders’ loan portfolios. NYDFS has entered into a series of consent...more

Regulators Zero In on AI

As previously discussed, financial services regulators are increasingly focused on how businesses use artificial intelligence (AI) and machine learning (ML) in underwriting and pricing consumer finance products. Although...more

Artificial Intelligence and Regulatory Compliance

Regulators at the state and federal level are increasing their scrutiny of businesses’ use of artificial intelligence (AI). For example, recently, representatives from the Office of the Comptroller of the Currency and the New...more

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