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
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
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
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
6/27/2025
/ Banking Sector ,
Banks ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
OCC ,
Prudential Regulation Authority (PRA) ,
Regulatory Reform ,
Regulatory Requirements ,
Risk Management
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
6/27/2025
/ Banking Sector ,
Banks ,
Consent Order ,
Corrective Actions ,
Enforcement Actions ,
Financial Institutions ,
New York ,
OCC ,
Regulatory Oversight ,
Regulatory Requirements ,
Risk Management ,
Strategic Planning
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
6/13/2025
/ Banking Sector ,
Banks ,
Dodd-Frank ,
Financial Institutions ,
Financial Regulatory Reform ,
Government Agencies ,
OCC ,
Preemption ,
Regulatory Agencies ,
Regulatory Oversight ,
Regulatory Requirements ,
State and Local Government
On May 23, the CFPB notified a Kentucky federal court that it now considers its own 2023 open banking rule “unlawful” and plans to set the rule aside. The Bureau announced its intent to seek summary judgement against the...more
On May 20, the U.S. Senate voted 66-32 to move forward with the Guardrails and Enforcement for Neutral Issuers of United States Stablecoins (GENIUS) Act (the “Act”), pushing the stablecoin bill past a major procedural hurdle....more
5/23/2025
/ Banking Sector ,
Cryptocurrency ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Government Agencies ,
Legislative Agendas ,
New Legislation ,
Proposed Legislation ,
Regulatory Requirements ,
Stablecoins
On April 16, the Colorado General Assembly enacted House Bill 25-1201, replacing the state’s prior money transmitter law with the Money Transmission Modernization Act (the “Act”). Modeled on the multistate framework developed...more
On April 18, the FDIC announced a consent order against a Delaware-based bank alleging that the bank engaged in unsafe and unsound banking practices and violated various federal consumer protection laws, including Section 5...more
On April 9, the Federal Reserve Bank of Kansas City published a research briefing examining how video game platforms are reshaping the digital payments landscape. As in-game purchases and platform-based transactions grow in...more
4/21/2025
/ Banking Sector ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Federal Reserve ,
Financial Institutions ,
FinTech ,
Payment Systems ,
Regulatory Requirements ,
Risk Management ,
Technology Sector ,
Video Games
On March 21, the U.S. Department of the Treasury submitted a report to the Office of Management and Budget affirming that all 11 programs administered by the Community Development Financial Institutions (CDFI) Fund are...more
On March 24, acting FDIC Chairman Travis Hill informed Congress that the agency is preparing to eliminate the use of “reputation risk” as a basis for supervisory criticism. In a letter to Rep. Dan Meuser (R-Pa.), Hill...more
On March 7, the OCC issued Interpretive Letter 1183 and an accompanying statement affirming prior guidance regarding whether national banks and federal savings associations may engage in cryptocurrency-related activities,...more
3/17/2025
/ Banking Sector ,
Blockchain ,
Cryptocurrency ,
Digital Assets ,
Financial Institutions ,
Financial Services Industry ,
Interpretive Letters ,
OCC ,
Payment Systems ,
Regulatory Requirements ,
Risk Management ,
Stablecoins
On February 25, a federal judge in the United District Court for the Eastern District of Kentucky approved a joint motion between the CFPB and banking trade groups to pause litigation over the agency’s 1033 open banking rule....more
On February 6, 2025, the U.S. District Court of the Northern District of Illinois declined to issue a preliminary injunction to stop an Illinois “swipe fee” law that would ban certain credit and debit card fees from applying...more
On January 23, 2025 the New York Department of Financial Services (NYDFS) announced proposed regulations to curb overdraft fees and insufficient funds fees charged by banks in New York. The proposed rules aim to protect...more
2/3/2025
/ Banking Sector ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Fees ,
Financial Institutions ,
New York ,
NYDFS ,
Overdraft Fees ,
Proposed Rules ,
Regulatory Agenda ,
Regulatory Requirements ,
Rulemaking Process ,
Unfair or Deceptive Trade Practices
On December 20, 2024, an Illinois federal court, in considering a motion for a preliminary injunction brought by the Illinois Bankers Association, American Bankers Association, and other trade groups, ruled that national...more
On November 12, the CFPB released a report analyzing federal and state-level privacy protections for consumer financial data.
The current federal framework for financial data privacy relies on the Gramm-Leach-Bliley Act...more
On October 31, the CFPB entered into a consent order with a Florida-chartered credit union for harming consumers in connection with the botched launch of a new online banking system, in violation of the Consumer Financial...more
On October 3, the OCC issued Bulletin 2024-29, providing guidance for managing credit risk in connection with refinancing commercial loans.
The bulletin is directed at all banks with commercial loan portfolios, and...more
The banking industry’s efforts to challenge a new Illinois law banning interchange fees, also known as “swipe fees,” on tax and tip payments gained significant momentum when the OCC criticized the law as an “ill-conceived”...more
An Oklahoma-based bank has been hit with a consent order from the FDIC after posting significant losses in its first year of operation. On June 28, the FDIC announced that it took an enforcement action against the bank...more
Florida is one of several states that has enacted “de-banking” legislation that requires financial institutions to provide consumers with fair access to financial products and services. On May 3, Governor DeSantis signed into...more
The Consumer Financial Protection Bureau (“CFPB”) published a report on Banking in Video Games and Virtual Worlds (“Report”) that warns of greater scrutiny of and enforcements against the financial services offered in games...more