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
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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
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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
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
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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
On July 16, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the federal banking agencies) jointly published a proposed rule...more
7/18/2025
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Comment Period ,
Community Reinvestment Act ,
Consumer Financial Products ,
CRA ,
Equal Access to Credit ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Lenders ,
Loans ,
Low-Income Issues ,
OCC ,
Proposed Rules ,
Regulatory Agenda ,
Regulatory Oversight ,
Regulatory Requirements
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
On May 9, the U.S. Senate Committee on Banking, Housing, and Urban Affairs announced that President Trump signed into law Chairman Tim Scott’s (R-SC) Congressional Review Act (CRA) resolution, effectively overturning the...more
5/13/2025
/ American Bankers Association ,
Banks ,
Biden Administration ,
Congressional Review Act ,
Consumer Financial Protection Bureau (CFPB) ,
Deregulation ,
Financial Regulatory Reform ,
Financial Services Industry ,
Overdraft Fees ,
Popular ,
Regulatory Reform ,
Trump Administration
In a significant policy shift under the Trump administration, the new Federal Housing Finance Agency (FHFA) Director Bill Pulte issued an order on March 25, 2025 terminating special purpose credit programs (SPCPs) supported...more
3/28/2025
/ Banks ,
Consumer Financial Products ,
ECOA ,
Equal Access to Credit ,
Fair Housing Act (FHA) ,
Fannie Mae ,
FHFA ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Freddie Mac ,
GSE ,
Housing Market ,
HUD ,
Lenders ,
Mortgages ,
Regulatory Reform ,
Regulatory Requirements ,
Trump Administration
On October 29, New Jersey Attorney General Matthew Platkin and the state’s Division on Civil Rights (DCR) released a report detailing the findings of a multi-year investigation into Republic First Bank (Republic) and its...more
11/1/2024
/ Banks ,
Consumer Financial Products ,
Discriminatory Lending Practices ,
Enforcement Actions ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Real Estate Transactions ,
Redlining
Tuesday, the League of Southeastern Credit Unions (LSCU) and the Virginia Credit Union League (VCUL) announced plans to merge, marking the first state league consolidation since 2022. According to the leagues’ combined...more
As discussed here, last week the U.S. Supreme Court issued its long-awaited decision in Community Financial Services Association of America, Limited (CFSA) v. Consumer Financial Protection Bureau (CFPB or Bureau) holding that...more
5/20/2024
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Constitutional Challenges ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Financial Protection Bureau v Community Financial Services Association of America Ltd ,
Dodd-Frank ,
Federal Funding ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
SCOTUS ,
Section 1071
For the last two years, the federal regulatory agencies have been waging a war on redlining by mortgage lenders — a war that shows no signs of abating.
Originally published in Law360 - December 12, 2023....more
3/12/2024
/ Banks ,
Consumer Financial Products ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Redlining
This week, the Texas Bankers Association, the Amarillo Chamber of Commerce, the American Bankers Association, the Chamber of Commerce of the United States of America, the Longview Chamber of Commerce, the Independent...more
As discussed here, on October 24, the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency finally issued their long-awaited final rule modernizing how they...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
2/1/2024
/ Automotive Loans ,
Banks ,
Class Action ,
Consumer Bankruptcy ,
Consumer Financial Products ,
Debt Collection ,
Digital Assets ,
Fair Lending ,
Financial Services Industry ,
FinTech ,
Mortgages ,
Student Loans ,
Tribal Loans ,
Uniform Commercial Code (UCC)
On August 28, the U.S. Department of Justice (DOJ) announced its eighth redlining settlement under its Combatting Redlining Initiative. The settlement between the DOJ and the American Bank of Oklahoma, which originated from a...more
8/31/2023
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Consent Order ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
ECOA ,
Enforcement Actions ,
Fair Housing Act (FHA) ,
FDIC ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Redlining ,
Settlement
On August 10, two credit union trade associations — Credit Union National Association (CUNA) and Cornerstone Credit Union League — and Rally Credit Union (collectively, Proposed Intervenors) filed an Unopposed Emergency...more
8/15/2023
/ American Bankers Association ,
Banks ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Financial Protection Bureau v Community Financial Services Association of America Ltd ,
Consumer Protection Act ,
Data Collection ,
Dodd-Frank ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
Regulatory Agencies ,
Reporting Requirements ,
SCOTUS ,
Section 1071 ,
Stays
On August 8, bankers associations from all 50 states sent a joint letter to the Consumer Financial Protection Bureau (CFPB or Bureau) urging it to stay enforcement and implementation of the small business data collection and...more
8/11/2023
/ American Bankers Association ,
Banks ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Financial Protection Bureau v Community Financial Services Association of America Ltd ,
Consumer Protection Act ,
Dodd-Frank ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
SCOTUS ,
Section 1071 ,
Stays
On June 29, the Federal Financial Institutions Examination Council (FFIEC) announced the availability of data on 2022 mortgage lending transactions reported under the Home Mortgage Disclosure Act (HMDA) by U.S. financial...more