The Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the “GENIUS Act” and the “Act”) establishes a regulatory infrastructure for defining, managing, custodying and issuing a specific kind of...more
6/24/2025
/ Cryptocurrency ,
Digital Assets ,
Digital Currency ,
FDIC ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Investment ,
OCC ,
Payment Systems ,
Popular ,
Regulatory Agenda ,
Regulatory Requirements ,
Service Professionals ,
Stablecoins ,
U.S. Treasury
Breaking news out of the New York legislature that they have passed the 2022 Amendments to the Uniform Commercial Code (UCC).
The amendments would now go to the governor....more
It has been difficult to keep up with all of the changes that have been happening with Consumer Financial Protection Bureau (“CFPB”) lawsuits and interpretations because the CFPB has not been sending out press releases...more
Since our last report on what is happening with the Consumer Financial Protection Bureau (“CFPB”) during this administration, we have seen the Trump nominee for Director of the CFPB retracted from consideration in front of...more
As of Wednesday, stablecoin bills in the House and the Senate have been voted out of committee and moved onto the floor of each house for a full vote....more
In the two weeks since our last update on what is happening with the Consumer Financial Protection Bureau ("CFPB"), the Trump administration has continued to take actions that make it seem as though they are intending to wind...more
We have been waiting to see how things are shaking out for the now-beleaguered Consumer Financial Protection Bureau (“CFPB”). A month out from Trump’s inauguration, we are still in a position of wondering if there will be a...more
We have reported on stablecoin regulation and legislation several times over the last few years, including on the most recent stablecoin legislation that appeared to have traction on a bi-partisan basis, the Lummis-Gillibrand...more
On February 5, the Federal Deposit Insurance Corporation (“FDIC”) released 175 documents related to supervision of banks it oversees that either engaged in or sought to engage in crypto-related activities. Acting Chairman...more
Effective January 30, the Securities & Exchange Commission ("SEC") rescinded the Staff Accounting Bulleting ("SAB") that has made engaging in crypto-related activities so perilous over the last couple of years, SAB-121,...more
On January 23, President Trump issued an Executive Order and accompanying Fact Sheet intending to promote “United States leadership in digital assets and financial technology while protecting economic liberty.” Entitled...more
The Congressional Review Act (“CRA”) is an interesting law that we really only think about when there is a change of party affiliation of an incoming President. Effectively, the CRA allows Congress to overturn rules that have...more
Checking in on what the Consumer Financial Protection Bureau (“CFPB”) has been up to for the last month, in case you missed it (and with some commentary)...more
10/10/2024
/ ATMs ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Credit ,
FDCPA ,
Financial Regulatory Reform ,
Financial Services Industry ,
Medical Debt ,
Mortgages ,
Regulation M ,
Regulation Z
On September 17th, the Federal Deposit Insurance Corporation ("FDIC") issued a proposed rule entitled “Recordkeeping for Custodial Accounts” with comments due sixty days from the date of publication in the Federal Register...more
On July 24th, the Consumer Financial Protection Bureau (CFPB) issued a new proposed rule “Streamlining Mortgage Servicing for Borrowers Experiencing Payment Difficulties”, with a comment period ending on September 9, 2024....more
7/29/2024
/ Chevron Deference ,
Comment Period ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Financial Regulatory Reform ,
Financial Services Industry ,
Mortgage Servicing Rules ,
Mortgages ,
Preemption ,
Proposed Rules ,
Regulatory Agenda
On March 5th the Consumer Financial Protection Bureau ("CFPB") announced that it had finalized its rule revisions to Regulation Z and the Official Staff Commentary regarding “Credit Card Penalty Fees.” See a redline of the...more
3/7/2024
/ CARD Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Debit and Credit Card Transactions ,
Federal Reserve ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Late Fees ,
Regulation Z ,
Rulemaking Process
On February 16, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a proposed rule addressing “Anti-Money Laundering Regulations for Residential Real Estate Transfers.” The proposed rule would, among other...more
2/26/2024
/ AML/CFT ,
Anti-Money Laundering ,
Beneficial Owner ,
BSA/AML ,
Corporate Transparency Act ,
Financial Regulatory Reform ,
FinCEN ,
Money Laundering ,
Proposed Rules ,
Real Estate Investments ,
Real Estate Transactions ,
Regulatory Agenda ,
Regulatory Requirements ,
Suspicious Activity Reports (SARs)
In January 2024, the Consumer Financial Protection Bureau ("CFPB") issued two proposed rules that, if implemented as written, would result in further whittling down overdraft or non-sufficient funds ("NSF") fees charged by...more
2/12/2024
/ Comment Period ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Insufficient Funds ,
Overdraft Fees ,
Regulation Z ,
Rulemaking Process ,
Truth in Lending Act (TILA)
The financial services regulatory agencies have rolled into 2024 as busy as ever. This list hits on some quick takes of developments in the last month; a summit, a meeting and a symposium involving hot topics such as...more
1/26/2024
/ Artificial Intelligence ,
CFTC ,
ETFs ,
FDIC ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Inflation Adjustments ,
Machine Learning ,
OCC ,
Regulatory Agenda ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Special Purpose Acquisition Companies (SPACs)
As we reported last week, the Consumer Financial Protection Bureau (“CFPB”) released a proposed rule addressing “personal data financial rights.” Comments are due on December 29, 2023....more
11/3/2023
/ Consumer Financial Protection Bureau (CFPB) ,
Data Protection ,
Electronic Payment Transactions ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Open Banking ,
Personal Data ,
Proposed Rules ,
Regulation E ,
Regulation Z
As we mentioned last week, the Federal Reserve Board (“FRB”) announced proposed changes to Regulation II (Debit Card Interchange Fees and Routing), which is the implementing regulation of the Durbin Amendment to the...more
11/3/2023
/ Comment Period ,
Debit and Credit Card Transactions ,
Debit Cards ,
Durbin Amendment Rules ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FRB ,
Interchange Fees ,
Regulation II ,
Regulatory Agenda
The Federal Reserve Board announced proposed changes to Regulation II (Debit Card Interchange Fees and Routing), which is the implementing regulation of the Durbin Amendment to the Dodd-Frank Act....more
10/30/2023
/ Comment Period ,
Debit and Credit Card Transactions ,
Debit Cards ,
Dodd-Frank ,
Durbin Amendment Rules ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FRB ,
Interchange Fees ,
Regulation II ,
Regulatory Agenda
On Tuesday, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a final rule to amend and update...more
On September 20th, the Consumer Financial Protection Bureau (“CFPB”) published guidance – Consumer Financial Protection Circular, 2023-03 – regarding the list of reasons that must be provided when an applicant is denied...more
9/21/2023
/ Adverse Action ,
Artificial Intelligence ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Discriminatory Lending Practices ,
ECOA ,
Fair Lending ,
Financial Regulatory Reform ,
Financial Services Industry ,
Machine Learning ,
New Guidance ,
Regulation B
On July 12, Senator Kirsten Gillibrand, a Democratic senator from New York who sits on the Senate Banking Committee, and Senator Cynthia Lummis, a Republican senator from Wyoming who sits on the Agriculture Committee, joined...more
8/2/2023
/ Bitcoin ,
CFTC ,
Cryptocurrency ,
Digital Assets ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
FinTech ,
Investment ,
Legislative Agendas ,
Office of Foreign Assets Control (OFAC) ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC)