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In a Surprising Switch, CFPB Now Seeks to Rewrite Open Banking Rule

On July 29, the U.S. District Court for the Eastern District of Kentucky granted the CFPB’s request to stay litigation challenging its open banking rule. The rule (previously discussed here) aimed to establish industry-wide...more

Georgia and Nebraska Update Money Transmission Statutes

Two states have recently finalized significant updates to their money transmission laws, signaling continued nationwide alignment with the Conference of State Bank Supervisors’ Model Money Transmission Modernization Act...more

Federal Court Rejects DOJ’s Request to End Oversight of Pennsylvania Bank’s Redlining Settlement

On July 23, the U.S. District Court for the Eastern District of Pennsylvania denied the Department of Justice’s motion to terminate a consent order requiring a Pennsylvania bank to implement a five-year fair lending...more

Consumer Groups Sue CFPB Over Delay in Section 1071

On July 23, a coalition of consumer advocacy organizations filed a lawsuit against the CFPB and Acting Director Russel Vought in the U.S. District Court for the District of Columbia, alleging the agency unlawfully delayed...more

Senate Confirms Jonathan Gould as Comptroller of the Currency

On July 10, 2025, the U.S. Senate confirmed Jonathan Gould as Comptroller of the Currency in a 50–45 vote. Gould will serve a five-year term and returns to the OCC, where he previously served as Chief Counsel and Senior...more

Fifth Circuit Upholds Dallas Fee-Cap & Installment Limits for Short-Term Loans

On July 1, 2025, the U.S. Court of Appeals for the Fifth Circuit affirmed a district court’s denial of a preliminary injunction sought by several short-term lenders challenging amendments to the City of Dallas’s short-term...more

Connecticut Updates Money Transmission Law to Cover Digital Wallets and Virtual Currency

On June 30, 2025, Connecticut Governor Ned Lamont signed Public Act No. 25-66, enacting broad revisions to Connecticut’s money transmission statutes. The new law, effective October 1, 2025, updates definitions, expands...more

Texas Court Vacates CFPB Medical Debt Reporting Rule

On July 11, the U.S. District Court for the Eastern District of Texas vacated the CFPB’s Medical Debt Rule, concluding that the rule exceeded the Bureau’s statutory authority under the Fair Credit Reporting Act (FCRA). The...more

Federal Banking Regulators Issue Joint Guidance on Crypto-Asset Safekeeping

On July 14, the OCC, Federal Reserve, and FDIC announced the release of a joint statement clarifying how existing laws and regulations apply to crypto-asset safekeeping services offered by banking organizations. The statement...more

NYDFS and Other State Regulators Impose $4.2 Million Penalty on Money Transmitter

On July 9, the New York Department of Financial Services (NYDFS), joined by regulators from five other states, entered into a multistate settlement with a money transmitter headquartered in New York. The $4.2 million consent...more

Rhode Island Enacts Ban on Reporting Medical Debt to Credit Bureaus

On June 26, Rhode Island Governor Dan McKee signed companion bills S 0169 and S 0172 into law, twin measures that amend the state’s Deceptive Trade Practices Act and Interest and Usury statute to impose some of the nation’s...more

CFPB Funding Cut Nearly 50% by “One Big Beautiful Bill Act”

On July 4, the “One Big Beautiful Bill Act,” was signed into law, which includes a provision to reduce the cap on the CFPB’s annual funding. The bill lowers the cap from 12% to 6.5% of the Federal Reserve’s total operating...more

DFPI Finalizes $300,000 Settlement with Crypto Kiosk Operator for Alleged Digital Asset Law Violations

On June 25, the California DFPI announced that it had finalized a consent order with a cryptocurrency kiosk operator, alleging violations of the Digital Financial Assets Law (DFAL) and the California Consumer Financial...more

CFPB Terminates Two Consent Orders Addressing Overdraft Fees and Mortgage Servicing Violations

On July 1, the CFPB terminated two separate consent orders, one involving a federal credit union and the other involving a national mortgage servicer. Both orders stemmed from 2024 enforcement actions and involved alleged...more

Eighth Circuit Vacates FTC’s “Click-to-Cancel” Negative Option Rule

On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the FTC’s “click-to-cancel” Negative Option Rule, holding that the FTC violated the FTC Act and the Administrative Procedure Act when it finalized the...more

HUD Requests Public Input on Buy Now Pay Later Loans and FHA Mortgage Eligibility

On June 24, the Department of Housing and Urban Development (HUD) issued a Request for Information (RFI) to evaluate how Buy Now Pay Later (BNPL) loans may affect FHA-insured mortgage underwriting. The RFI seeks comment on...more

Federal Reserve Board Removes Reputational Risk from Examination Ratings

On June 23, the Federal Reserve Board announced that reputational risk will no longer be a component of its bank-examination program. The same day, the Board released a revised edition of its Guidelines for Rating Risk...more

Illinois District Court Denies Motion to Vacate CFPB Redlining Settlement

On June 12, the U.S. District Court for the Northern District of Illinois denied a motion to vacate a November 2024 stipulated final judgement and order requiring a Chicago-based mortgage broker to pay a $105,000 civil money...more

OCC Enters Consent Orders Against New York-based Bank

On May 14, the OCC entered into a formal agreement with a New York-based bank after determining that the institution is in “troubled condition.” In its findings, the OCC cited alleged unsafe or unsound practices tied to the...more

CFPB Moves Forward with Debt Relief Suit Over $3.4M in Alleged Advance Fees

On June 10, the CFPB moved to reopen its 2021 enforcement action against the final remaining defendant in a student debt relief case involving over $3.4 million in alleged illegal advance fees. The Bureau, under Acting...more

OCC Rejects Calls to Roll Back Preemption Rules

On June 9, Acting Comptroller of the Currency Rodney Hood issued a letter rejecting the Conference of State Bank Supervisors’ (CSBS) request that the OCC rescind its 2011 preemption regulations. The OCC ‘s letter signals...more

Louisiana and Connecticut Advance Earned Wage Access Laws

Louisiana and Connecticut recently passed legislation establishing regulatory frameworks for earned wage access (EWA) providers. Connecticut’s SB 5140 passed the legislature on June 4 and awaits Governor Ned Lamont’s...more

DOJ Moves to End $13 Million Redlining Consent Order

On May 28, the U.S. Department of Justice filed a motion to terminate its redlining consent order against a New Jersey-based bank. The five-year order, entered in September 2022, resolved allegations that the banks violated...more

Nevada Enacts Law Allowing Remote Licensing for Internet Consumer Lenders

On May 28, Nevada Governor Joe Lombardo approved SB 437, creating a new framework for internet-based consumer lenders that lend to Nevada residents. The law defines an “Internet consumer lender” as any entity that exclusively...more

Fourth Circuit Expands FCRA Liability: Legal Inaccuracies Now Actionable

On March 14, the U.S. Court of Appeals for the Fourth Circuit vacated the dismissal of a lawsuit alleging a failure to reasonably investigate a disputed debt. The lawsuit concerned a consumer who disputed a debt that she...more

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