On July 14, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (the Board), and the Federal Deposit Insurance Corporation (FDIC) jointly issued a statement addressing the...more
7/17/2025
/ Anti-Money Laundering ,
Banking Sector ,
Banks ,
Cryptocurrency ,
Digital Assets ,
FDIC ,
Federal Reserve ,
Fiduciary Duty ,
Financial Institutions ,
Investment ,
Joint Statements ,
OCC ,
Regulatory Requirements ,
Risk Management
On June 26, the Conference of State Bank Supervisors (CSBS) released new guidance regarding the treatment of virtual currency in the calculation of a licensee’s tangible net worth under the Money Transmission Modernization...more
7/9/2025
/ Banking Sector ,
Cryptocurrency ,
CSBS ,
Digital Assets ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Money Transmission Act ,
Money Transmitter ,
New Guidance ,
Regulatory Oversight ,
Regulatory Requirements ,
State and Local Government ,
Virtual Currency
On June 24, Senate Banking Chairman Tim Scott (R-SC), Subcommittee on Digital Assets Chair Cynthia Lummis (R-WY), Senator Thom Tillis (R-NC), and Senator Bill Hagerty (R-TN) released a set of guiding principles for the...more
6/27/2025
/ Cryptocurrency ,
Digital Assets ,
Financial Institutions ,
Financial Markets ,
Financial Regulatory Reform ,
Investment ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Reform ,
Securities Regulation ,
Senate Banking Committee ,
Stablecoins
The Consumer Financial Protection Bureau (CFPB or Bureau) announced a significant shift in its enforcement priorities, choosing not to prioritize actions related to Buy Now, Pay Later (BNPL) loans under the Truth in Lending...more
5/9/2025
/ Buy Now Pay Later (BNPL) ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Enforcement Priorities ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Lenders ,
Loans ,
Military Service Members ,
Regulation Z ,
Small Business ,
Veterans
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....more
4/16/2025
/ Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
IRS ,
Layoffs ,
Regulatory Reform ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Trump Administration
On April 9, the House of Representatives passed two Congressional Review Act (CRA) joint resolutions aimed at nullifying certain Consumer Financial Protection Bureau (CFPB) rules finalized in the final days of the...more
4/14/2025
/ Congressional Review Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Nullification ,
Overdraft Fees ,
Regulatory Reform ,
Regulatory Requirements
The Federal Communications Commission (FCC) issued an order extending the effective date of certain parts of § 64.1200(a)(10) of its rules under the Telephone Consumer Protection Act (TCPA) to April 11, 2026....more
4/8/2025
/ Effective Date ,
FCC ,
Financial Institutions ,
Financial Services Industry ,
Healthcare ,
Healthcare Facilities ,
New Regulations ,
Regulatory Requirements ,
Robocalling ,
TCPA ,
Telecommunications ,
Telemarketing ,
Text Messages ,
Time Extensions
Last Friday, the Federal Deposit Insurance Corporation (FDIC) announced the rescission of Financial Institution Letter (FIL-16-2022) and issued new guidance clarifying the process for FDIC-supervised institutions to engage in...more
4/1/2025
/ Banks ,
Consumer Financial Products ,
Cryptocurrency ,
Digital Assets ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
New Guidance ,
OCC ,
Regulatory Oversight
On March 7, the Office of the Comptroller of the Currency (OCC) issued a significant update regarding the involvement of national banks and federal savings associations in cryptocurrency activities. Interpretive Letter 1183...more
3/13/2025
/ Banks ,
Blockchain ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Interpretive Letters ,
OCC ,
Regulatory Requirements ,
Risk Management
Recently, the Federal Deposit Insurance Corporation (FDIC) released 175 documents concerning its supervision of banks engaged in, or seeking to engage in, crypto-related activities. This release marks a significant step...more
We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures, consumer financial services providers faced a challenging...more
2/17/2025
/ Automotive Loans ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Enforcement Actions ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
Regulatory Agenda ,
Regulatory Requirements ,
TCPA ,
UDAAP ,
Uniform Commercial Code (UCC)
On January 27, a three-judge panel of the U.S. Court of Appeals for the Fourth Circuit issued a significant opinion holding that the Servicemembers Civil Relief Act (SCRA) does not prohibit the enforcement of arbitration...more
1/29/2025
/ Appeals ,
Arbitration ,
Arbitration Agreements ,
Class Action ,
Consumer Financial Contracts ,
Consumer Financial Products ,
Dispute Resolution ,
Federal Arbitration Act ,
Financial Institutions ,
Financial Services Industry ,
Mandatory Arbitration ,
Military Lending Act ,
Servicemembers Civil Relief Act (SCRA)
On January 10, the Consumer Financial Protection Bureau (Bureau) issued a notice of proposed interpretive rule (Proposed Rule). The deadline for comments is March 31, 2025. The Proposed Rule would apply the Electronic Fund...more
Recently, the Eastern District of Kentucky denied a motion to dismiss under the Fair Credit Reporting Act (FCRA) after finding the plaintiffs alleged sufficient facts to support a reasonable inference that credit reports were...more
1/8/2025
/ Class Action ,
Compliance ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Privacy Rights ,
Credit Reports ,
Data Privacy ,
Data Security ,
Fair Credit Reporting Act (FCRA) ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders
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...more
12/11/2024
/ CFPB v Community Financial Services Association of America ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Credit Reports ,
Enforcement Actions ,
Exploitation ,
Fair Credit Reporting Act (FCRA) ,
Fannie Mae ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Financial Services Industry ,
Freddie Mac ,
Late Fees ,
Student Loans
Earlier this month, we discussed the lawsuit filed by ACA International, LLC and Collection Bureau Services, Inc. in the U.S. District Court for the District of Columbia against the Consumer Financial Protection Bureau (CFPB...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...more
11/13/2024
/ Affordable Housing ,
Artificial Intelligence ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
ECOA ,
Enforcement Actions ,
FDIC ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Lenders ,
Popular ,
Underserved Locations ,
Unfair or Deceptive Trade Practices
In the latest episode of The Crypto Exchange, host Ethan Ostroff is joined by colleagues Brett Broczkowski and Mike Lowe to discuss the intersection of crime and cryptocurrency, with a focus on the challenges financial...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...more
11/6/2024
/ Centers for Medicare & Medicaid Services (CMS) ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
FHFA ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Financial Services Industry ,
Freddie Mac ,
Geographic Targeting Order ,
HUD ,
Medicare ,
Redlining ,
Securities Regulation ,
Unfair or Deceptive Trade Practices
This week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued its final rule on personal financial data rights, purportedly aimed at enhancing consumer control over their financial data and promoting competition...more
10/24/2024
/ Banks ,
Consumer Data Requests ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Data Management ,
Dodd-Frank ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Open Banking
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...more
10/23/2024
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Financial Services Industry ,
Mortgages ,
Negative Option Rule ,
Proposed Legislation ,
Redlining ,
Securities Regulation ,
Student Loans ,
Subscription Services
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...more
10/8/2024
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Debt Collectors ,
FCC ,
FDIC ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Proposed Rules ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Truth in Lending Act (TILA)
On October 1, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an advisory opinion aimed at debt collectors and emphasizing their obligations under the Fair Debt Collection Practices Act (FDCPA) and Regulation...more
10/4/2024
/ Advisory Opinions ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Consumer Reporting Agencies ,
Creditors ,
Debt Collection ,
Debt Collectors ,
FDCPA ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Healthcare ,
Medical Debt ,
Proposed Rules ,
Regulation F ,
Regulation V
On September 29, California Governor Gavin Newsom signed Assembly Bill (AB) 1934 into law, marking a significant update to California’s Digital Financial Assets Law (DFAL). In addition to extending the compliance deadline for...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...more
10/3/2024
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Debt Collection ,
DIDMCA ,
FDCPA ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Proposed Rules ,
Regulatory Agenda