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District Court Vacates Regulation II’s Debit Card Interchange Fee Standard

On August 6, the US District Court for the District of North Dakota, in Corner Post, Inc. v. Bd. of Governors of Fed. Rsrv. Sys., vacated the entirety of Regulation II – the Federal Reserve Board’s framework for setting debit...more

Executive Order Guarantees Efforts Against Debanking Will Continue

On Thursday, August 7, 2025, President Donald Trump signed an executive order (EO), “Guaranteeing Fair Banking Access for All Americans,” aimed at combatting “politicized or unlawful debanking.” Debanking generally refers to...more

US DOJ Memo Clarifies DEI Compliance for Federal Funding Recipients

On July 30, 2025, US Attorney General Pam Bondi released a memo to all federal agencies titled “Guidance for Recipients of Federal Funding Regarding Unlawful Discrimination.” This document clarifies how federal...more

CFPB Announces Plan to Review Offenses Carrying Criminal Penalties

On June 27, the Consumer Financial Protection Bureau (CFPB) issued a policy statement, “Guidance on Referrals for Potential Criminal Enforcement,” which outlines its plan to address criminal regulatory offenses within its...more

CFPB Issues Interim Final Rule Extending Small Business Lending Rule Compliance Deadlines

The Consumer Financial Protection Bureau (CFPB) recently issued an interim final rule (2025 interim final rule) delaying compliance deadlines for a second time for its small business lending data collection rule, which...more

California DFPI Issues Annual Report Detailing Key Consumer Protection Accomplishments

The California Department of Financial Protection and Innovation (DFPI) released its fourth annual report highlighting key accomplishments from 2024 pursuant to its authority under the California Consumer Financial Protection...more

CFPB Moves to Vacate Its Own Open Banking Rule Citing Legal Deficiencies and Overreach

On May 30, 2025, the Consumer Financial Protection Bureau (CFPB) took the rare step of asking the US District Court for the Eastern District of Kentucky to vacate the CFPB’s own final rule implementing Section 1033 of the...more

Trump CFPB Asserts Narrower Role for State Enforcement of Federal Consumer Law

On May 15, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule that rescinded a May 2022 interpretive rule regarding the extent of states’ enforcement authority under Section 1042 of the Consumer...more

CFPB Withdraws Guidance Documents in Shift from Nonbinding Policymaking

After ordering the review of all existing guidance put forth by the Consumer Financial Protection Bureau (CFPB), acting CFPB Director Russell Vought announced the withdrawal of almost 70 guidance documents dating back to the...more

FTC Delays Enforcement of Amended Negative Option Rule

On May 9, the Federal Trade Commission (FTC) voted unanimously to delay enforcement of most portions of its amended Negative Option Rule (rule) by 60 days, shifting the compliance deadline for these portions from May 14 to...more

Executive Order Seeks to Eliminate Federal Deployment of Disparate Impact Theory of Discrimination

In an April 23 executive order titled, “Restoring Equality of Opportunity and Meritocracy,” the Trump administration declared it federal policy to eliminate the use of disparate impact liability “in all contexts to the...more

Slimmed-Down CFPB to Focus on Bank Oversight, Concrete Consumer Harm

On April 16, the Consumer Financial Protection Bureau (CFPB) sent an internal memorandum to CFPB staff describing its 2025 supervisory and enforcement priorities. Not surprisingly, the memo highlights its intended departure...more

New York Legislature Aims to Fill Federal Consumer Protection Void

On March 13, 2025, New York legislators introduced a bill backed by New York Attorney General Letitia James to expand the state’s current consumer protection law to cover “unfair” and “abusive” practices, and not just...more

CFPB Explores Options for Bringing Digital Payments Providers Under Privacy and Payments Laws

On January 10, 2025, the Consumer Financial Protection Bureau (CFPB) initiated rulemaking processes to examine and create a framework regarding data privacy and consumer protections in the digital payments industry. In a...more

CFPB Proposes New Rules That, If Finalized, Would Significantly Expand FCRA’s Reach

On December 3, 2024, the Consumer Financial Protection Bureau (CFPB) issued a notice of proposed rulemaking (NPR) – Protecting Americans from Harmful Data Broker Practices. The CFPB’s proposal would amend Regulation V, which...more

CFPB Asserts State Consumer Privacy Laws Do Not Sufficiently Protect Consumer Financial Data

The Consumer Financial Protection Bureau (CFPB) published a report on November 12, 2024, examining state and federal privacy protections for consumer financial data....more

CFPB Says FCRA May Govern Background Report Providers and Users, Including Tech Companies

On October 24, 2024, the Consumer Financial Protection Bureau (CFPB) issued a consumer financial protection circular explaining that background reports, including scores, obtained from third parties and “used by employers to...more

CFPB Finalizes Section 1033 Rule on Personal Financial Data Rights

On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) released its long-awaited final rule implementing Section 1033 of the Consumer Financial Protection Act (CFPA) concerning personal financial data rights....more

FTC Finalizes Negative Option Rule Governing Subscriptions and Trial Offers

The Federal Trade Commission (FTC) has released its long-anticipated Negative Option Rule. The rule defines a negative option feature as “a provision of a contract under which the consumer’s silence or failure to take...more

Federal Housing Administration Publishes Draft Updates to Its Cyber Reporting Requirements

On September 30, 2024, the Federal Housing Administration (FHA) published a draft Mortgagee Letter (ML) with updated cyber incident reporting requirements and a call for interested stakeholders to provide feedback to the...more

CFPB Challenges Financial Institutions to Produce Evidence of Affirmative Consent to Overdraft Fees

On September 17, 2024, the Consumer Financial Protection Bureau (CFPB) issued a circular explaining that financial institutions may violate the Electronic Fund Transfer Act (EFTA) and its implementing regulation, Regulation...more

CFPB Deems Contracts for Deed ‘Credit’ Subject to Regulation Z

On August 13, 2024, the Consumer Financial Protection Bureau (CFPB) issued an advisory opinion stating that contracts for deed are “credit” under Regulation Z, and therefore subject to its myriad requirements. Unlike a...more

CFPB Warns That Confidentiality Agreements May Violate Employee Whistleblower Protections

On July 24, 2024, the Consumer Financial Protection Bureau (CFPB) issued a circular explaining that confidentiality or nondisclosure agreements may chill whistleblowing activity and therefore violate the CFPB’s whistleblower...more

US Supreme Court’s October 2023 Term Administrative Law Trilogy – Holdings, Analyses and Implications of Jarkesy, Loper Bright and...

The October 2023 term of the US Supreme Court (SCOTUS) saw a trilogy of decisions that challenge long-settled assumptions about the authority of federal agencies and upend long-standing doctrines of administrative law: SEC v....more

Federal Regulators Act to Enhance Property Valuations During Mortgage Origination Process

On July 17 and 18, 2024, federal financial regulators adopted rules and guidance setting forth expectations in the mortgage industry that originators properly oversee use of automated valuation models (AVMs) and entertain...more

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