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New Lessons in Regulation, August 2025 - FDIC Revisits Rule on Deposit Insurance Signage

On August 19, the FDIC Board unanimously approved issuance of a proposed rule that seeks to amend advertising disclosures and signage regarding deposit insurance. In 2023, the FDIC updated its rules regarding required...more

Use of Payment Stablecoins as Margin and Collateral Under the GENIUS Act

Introduction The Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the “GENIUS Act” or the “Act”) establishes a legal framework for defining, issuing, custodying and managing a specific kind of...more

Global Moves, Digital Shifts, July 2025 - Federal Banking Regulators on Crypto-Asset Safekeeping

Just days prior to the passage of the GENIUS Act on stablecoins by Congress, on July 14th, the Federal Reserve, Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (collectively, the...more

Operation and Structure of the GENIUS Act of 2025 on Payment Stablecoins

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

Digital Assets-Focused UCC Amendments Pass New York Legislature

On June 11, 2025, the New York State Senate passed a bill adopting the 2022 Amendments to the Uniform Commercial Code (UCC). The 2022 Amendments have now been passed by both houses of the New York legislature, and can be...more

Heating Up, June 2025 - OCC Defends Federal Bank Preemption

In response to a request from the Conference of State Bank Supervisors (“CSBS”), Acting Comptroller of the Currency, Rodney E. Hood, decisively defended OCC regulations regarding the ability of national banks and Federal...more

Heating Up, June 2025 - 2022 Amendments Pass Both Houses of NY Legislature

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

Heating Up, June 2025 - Changes to CFPB Actions and Interpretations

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

Rules in Motion, May 2025 - Another Update on the CFPB

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

Certainty and Uncertainty, May 2025 - Passive Trusts in Maryland — Progress Regarding the Emergency Regulations

As we reported previously, the Maryland Office of Financial Regulation (“OFR”) issued emergency regulations this past January which indicated that passive trusts holding residential mortgage loans, even those used as part of...more

Certainty and Uncertainty May 2025 - CFPB v. NCSLT Again Again Again

As if the saga of litigation involving the Consumer Financial Protection Bureau (“CFPB”) and National Collegiate Master Student Loan Trusts (“NCSLT”) that has been going on since 2017 has not been protracted and complicated...more

Certainty and Uncertainty, May 2025 - Emerging Market Trends in Derivatives Industry

In the post-pandemic world, several trends are developing that will fundamentally change the way financial market participants manage commercial risk or trade traditional and rapidly evolving novel assets, while new classes...more

New Regulatory Priorities Spring Into Focus, April 2025 - Stablecoin Bills Moving to the Floor of the Senate and the House

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

Regulation in Flux, March 2025 - Trump's War on Consumer Protection, Humph(rey)

We have been following closely developments with the Consumer Financial Protection Bureau (“CFPB”) and the Trump/Musk administration (see here and here), and while we have a few updates on the CFPB, Trump and Musk have taken...more

Amid Chaos, Regulatory Change Continues Apace, March 2025 - The CFPB Is Dead, Long Live the CFPB

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

What is Happening With the CFPB?

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

New and Improved Stablecoin Legislation

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

Hester Peirce's Journey and Crypto Task Force

While some of the crypto developments we have reported on in this edition of Cabinet News & Views have had a distinctively partisan bent to them, the departure of Gary Gensler from the Securities & Exchange Commission...more

FDIC Acting Chair Hill Orders Release of Trove of Crypto-Related Documents

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

SEC Rescinds Crypto Interpretive Guidance That Has Hamstrung Industry

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

Crypto Capital of the Planet, but Without CBDCs

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

It’s Been Two Weeks and We Have a 2025 Crypto Compendium

The volume of news coming out from regulatory Washington, spurred by Executive Orders and new agency heads has been impressive since Trump took office on January 20. But, the amount of movement regarding regulation of crypto...more

Trusts Holding Loans Need Licensing, Says Maryland Office of Financial Regulation

On January 10, 2025, the Maryland Office of Financial Regulation issued emergency regulations revised to clarify that “passive trusts” holding residential mortgage loans must obtain a Mortgage Lender License and if the trusts...more

Maryland Emergency Regulations

On January 10, 2025, the Maryland Office of Financial Regulation issued emergency regulations revised to clarify that “passive trusts” holding residential mortgage loans must obtain a Mortgage Lender License and if the trusts...more

CFPB Continues Mad Race to Trump’s Inauguration

Since our last Cabinet News & Views issue on December 19, the Consumer Financial Protection Bureau (“CFPB”) has finalized yet another rule, this one addressing the circumstances under which medical bills should be removed...more

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