On September 8, the Office of the Comptroller of the Currency (OCC) took significant action to “depoliticize” the federal banking system by issuing two bulletins to banks that further the goals of Executive Order 14331...more
9/10/2025
/ Anti-Money Laundering ,
Banks ,
Community Reinvestment Act ,
Data Privacy ,
Enforcement Priorities ,
Financial Institutions ,
Financial Regulatory Reform ,
OCC ,
Regulatory Requirements ,
Risk Management ,
Suspicious Activity Reports (SARs)
On April 16, the Consumer Financial Protection Bureau released a memo to staff outlining its new supervision and enforcement priorities for 2025. These priorities appear to be intended to reverse some of the more prominent...more
9/4/2025
/ Banks ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Deregulation ,
Enforcement Priorities ,
Fair Lending ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Mortgages ,
Nonbank Firms ,
Regulatory Reform ,
Trump Administration
On August 29, the Federal Deposit Insurance Corporation (FDIC) announced updates to its Consumer Compliance Examination Manual, marking a pivotal shift in how potential discrimination under the Equal Credit Opportunity Act...more
9/4/2025
/ Banks ,
Consumer Financial Products ,
Disparate Impact ,
Disparate Treatment ,
ECOA ,
Executive Orders ,
Fair Housing Act (FHA) ,
Fair Lending ,
FDIC ,
Financial Institutions ,
Financial Services Industry ,
Government Agencies ,
Regulatory Reform ,
Trump Administration ,
Unfair or Deceptive Trade Practices
In this episode of The Consumer Finance Podcast, Chris Willis and Louis Manetti delve into the evolving legal landscape surrounding the statute of limitations for mortgage foreclosures in Illinois. With recent cases...more
On August 26, the U.S. Small Business Administration (SBA) took action to enforce President Trump’s directive by issuing a letter to its network of over 5,000 lenders. This letter mandates the cessation of alleged politicized...more
8/29/2025
/ Banks ,
Consumer Financial Products ,
Enforcement Actions ,
Executive Orders ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Lenders ,
Popular ,
Regulatory Requirements ,
Reporting Requirements ,
SBA ,
Small Business Loans ,
Trump Administration
The Consumer Financial Protection Bureau (CFPB or Bureau) is taking a significant step to modify its supervisory approach to nonbanks by publishing a proposed rule advancing a more stringent definition of “risks to consumers”...more
8/29/2025
/ Comment Period ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Financial Regulatory Reform ,
Financial Services Industry ,
Non-Bank Lenders ,
Non-Depository Institutions ,
Proposed Rules ,
Regulatory Agenda ,
Regulatory Oversight ,
Regulatory Reform ,
Risk Management ,
Rulemaking Process ,
Statutory Interpretation ,
Supervision ,
Supervisory Guidance
In this episode of The Consumer Finance Podcast, Chris Willis, Heryka Knoespel, and Lori Sommerfield discuss overdraft and deposit account fees as they continue to dive into the CFPB's guidance withdrawal. They highlight the...more
As has been well-documented, the Consumer Financial Protection Bureau (CFPB or Bureau) is navigating a period of significant uncertainty. Just last week, the U.S. Court of Appeals for the District of Columbia vacated a...more
8/22/2025
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
ECOA ,
Financial Services Industry ,
Hiring & Firing ,
Layoffs ,
Mortgage Loan Originators ,
Mortgages ,
Open Banking ,
Payday Lending Rule ,
Regulatory Agenda ,
Rulemaking Process ,
Small Business ,
UDAAP
On August 8, the Consumer Financial Protection Bureau (CFPB or Bureau) published a series of proposed rules aimed at redefining what constitutes a “larger participant” in several key financial markets. Under § 1024 of the...more
8/22/2025
/ Automotive Industry ,
Comment Period ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Bureaus ,
Debt Collectors ,
Financial Regulatory Reform ,
Financial Services Industry ,
Money Transfer ,
Non-Bank Lenders ,
Proposed Rules ,
Public Comment ,
Regulatory Agenda ,
Regulatory Oversight ,
Remittance Transfer Rule
On August 15, the U.S. Court of Appeals for the District of Columbia issued a decision in the case of National Treasury Employees Union (NTEU) v. Consumer Financial Protection Bureau (CFPB or Bureau). The appellate court...more
8/18/2025
/ Administrative Procedure Act ,
Appeals ,
Constitutional Challenges ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
Government Agencies ,
Hiring & Firing ,
Jurisdiction ,
Preliminary Injunctions ,
Regulatory Violations ,
Statutory Interpretation ,
Title X ,
Trump Administration ,
Unions ,
Vacated
In this episode of The Consumer Finance Podcast, Chris Willis is joined by veteran litigators Jason Manning and Carter Nichols to explore litigation implications following the CFPB’s withdrawal of nearly 70 pieces of informal...more
In this crossover episode of The Consumer Finance Podcast and Payments Pros, Chris Willis, Jason Cover, and Taylor Gess expand on the Point-of-Sale Finance Series to focus on leases and rent-to-own (RTO) models. This...more
In this special joint episode of The Consumer Finance Podcast and Payments Pros, Chris Willis, co-leader of Troutman Pepper Locke's Consumer Financial Services Regulatory Practice, is joined by Keith Barnett and Jason Cover...more
In this special joint episode of The Consumer Finance Podcast and Payments Pros, Chris Willis, co-leader of Troutman Pepper Locke's Consumer Financial Services Regulatory Practice, is joined by Keith Barnett and Jason Cover...more
On June 25, the California Department of Financial Protection and Innovation (DFPI) entered a consent order with Coinme, Inc., a cryptocurrency “ATM” operator, for noncompliance with the California’s Consumer Financial...more
7/22/2025
/ ATMs ,
California ,
Consent Order ,
Cryptocurrency ,
Department of Financial Protection and Innovation (DFPI) ,
Digital Assets ,
Disclosure Requirements ,
Enforcement Actions ,
Financial Services Industry ,
Regulatory Requirements ,
Regulatory Violations
On July 10, the U.S. Department of Housing and Urban Development (HUD) and the Office of Management and Budget (OMB) jointly announced the effective disbandment of the interagency Property Appraisal and Valuation Equity...more
7/17/2025
/ Appraisal ,
Biden Administration ,
Discrimination ,
Fair Housing Act (FHA) ,
Federal Housing Administration (FHA) ,
Housing Discrimination ,
HUD ,
OMB ,
Real Estate Market ,
Real Estate Transactions ,
Regulatory Reform ,
Trump Administration
In this episode of The Consumer Finance Podcast, Chris Willis is joined by veteran litigators and Troutman Pepper Locke Partners Mary Zinsner and Heryka Knoespel to dissect a groundbreaking Fourth Circuit decision on bank...more
On July 14, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2025-16, announcing the removal of references to disparate impact liability from the “Fair Lending” booklet of the Comptroller’s Handbook and...more
7/16/2025
/ Anti-Discrimination Policies ,
Banks ,
Borrowers ,
Consumer Financial Products ,
Deregulation ,
Discriminatory Lending Practices ,
Disparate Impact ,
Equal Access to Credit ,
Executive Orders ,
Fair Lending ,
Financial Regulatory Reform ,
Financial Services Industry ,
Handbooks ,
Lenders ,
OCC ,
Regulatory Authority ,
Regulatory Requirements ,
Trump Administration
In this crossover episode of The Consumer Finance Podcast and Payments Pros, Chris Willis, Jason Cover, and Taylor Gess continue the Point-of-Sale Finance Series to discuss licensed lending and bank model lending programs....more
n June 23, the Consumer Financial Protection Bureau (CFPB or Bureau) released an update to its 2015 report on Americans who did not have a credit record (credit invisibles) or who had insufficient credit history to have a...more
7/3/2025
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Protection Laws ,
Credit Reports ,
Credit Scores ,
Data Collection ,
Debt ,
Equal Access to Credit ,
Loans ,
Regulatory Reform ,
Student Loans
Today, the Consumer Financial Protection Bureau (CFPB or Bureau) published a policy statement in the Federal Register outlining its approach to addressing criminally liable regulatory offenses. This publication comes in...more
6/27/2025
/ Consumer Financial Protection Bureau (CFPB) ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Deregulation ,
Enforcement Actions ,
Enforcement Priorities ,
Executive Orders ,
Financial Crimes ,
Financial Regulatory Reform ,
Penalties ,
Regulatory Agenda ,
Regulatory Reform ,
Reporting Requirements ,
Trump Administration ,
White Collar Crimes
On June 20, the Consumer Financial Protection Bureau (CFPB or Bureau) filed a statement of interest in support of converting the bankruptcy case of Synapse Financial Technologies, Inc. from Chapter 11 to Chapter 7, rather...more
6/26/2025
/ Bankruptcy Code ,
Chapter 11 ,
Chapter 7 ,
Commercial Bankruptcy ,
Consumer Financial Protection Bureau (CFPB) ,
Conversion ,
Depository Institutions ,
Enforcement Actions ,
Financial Institutions ,
FinTech ,
Investment Funds ,
Unfair or Deceptive Trade Practices
In this episode of The Consumer Finance Podcast, Chris Willis and Lori Sommerfield discuss the latest regulatory, legislative, and litigation developments under the Americans with Disabilities Act (ADA), as accessibility of...more
In this special crossover episode between Moving the Metal and The Consumer Finance Podcast, Brooke Conkle, Chris Capurso, and Chris Willis analyze the first 100 days of the second Trump administration, focusing on its impact...more
The Consumer Financial Protection Bureau (CFPB or Bureau) published in the Federal Register an interim final rule extending compliance dates for its 2023 small business lending rule under the Equal Credit Opportunity Act...more
6/19/2025
/ Compliance Dates ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Data Collection ,
ECOA ,
Filing Deadlines ,
Final Rules ,
Financial Institutions ,
Interim Final Rules (IFR) ,
Minority-Owned Businesses ,
Regulation B ,
Reporting Requirements ,
Rulemaking Process ,
Section 1071 ,
Small Business Loans ,
Women-Owned Businesses