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
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
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
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
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 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
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
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
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
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
6/13/2025
/ Consumer Lenders ,
Consumer Protection Laws ,
Disclosure Requirements ,
Earned Wage Access ,
Fees ,
Financial Services Industry ,
Loans ,
New Legislation ,
Regulatory Requirements ,
State and Local Government ,
State Legislatures
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
On May 27, the CFPB filed a notice of dismissal with prejudice in its lawsuit against a lease-to-own fintech provider. The lawsuit, filed in July 2023, alleged that the company’s rental-purchase agreements violated several...more
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 May 12, the CFPB formally withdrew nearly 70 guidance materials—including policy statements, advisory opinions, circulars, and interpretive rules—through a Federal Register notice issued by Acting Director Russell...more
5/16/2025
/ Advisory Opinions ,
Buy Now Pay Later (BNPL) ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Earned Wage Access ,
Federal Register ,
Financial Services Industry ,
Regulatory Authority ,
Regulatory Reform ,
Regulatory Requirements ,
UDAAP ,
Unfair or Deceptive Trade Practices
On May 9, President Trump signed a Congressional Review Act resolution repealing the CFPB’s final rule restricting overdraft fees at large financial institutions. The rule, originally finalized under the Biden administration,...more
5/16/2025
/ Banks ,
Biden Administration ,
Congressional Review Act ,
Consumer Financial Protection Bureau (CFPB) ,
Final Rules ,
Financial Institutions ,
Overdraft Fees ,
Popular ,
Regulatory Reform ,
Regulatory Requirements ,
Trump Administration ,
Truth in Lending Act (TILA)
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 15, Judge Mark T. Pittman of the U.S. District Court for the Northern District of Texas entered an Order and Final Judgement vacating the CFPB’s 2024 credit card late fee rule (previously discussed here) for...more
On April 30, the CFPB announced it will deprioritize enforcement and supervision of its small business lending data collection rule for institutions not covered by the stay issued by the U.S. Court of Appeals for the Fifth...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 April 4, the Securities and Exchange Commission’s (SEC) Division of Corporation Finance issued a statement clarifying that reserve-backed U.S. dollar stablecoins are not securities, at least under current law and...more
4/21/2025
/ Cryptocurrency ,
Digital Assets ,
Financial Regulatory Reform ,
FinTech ,
New Guidance ,
Proposed Legislation ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Stablecoins ,
Technology Sector
On April 11, the CFPB announced that it will not prioritize enforcement or supervision against nonbank financial companies that miss registration deadlines under its Repeat Offender Registry. The Bureau also stated that it is...more
On April 4, the California Department of Financial Protection and Innovation (DFPI) issued proposed regulations under the Digital Financial Assets Law (DFAL). The proposal provides clarification on DFAL’s licensing framework...more
4/14/2025
/ California ,
Cryptocurrency ,
Department of Financial Protection and Innovation (DFPI) ,
Digital Assets ,
FinTech ,
Government Agencies ,
Licensing Rules ,
Proposed Rules ,
Regulatory Agenda ,
Regulatory Requirements ,
Rulemaking Process