Deposit Account Litigation: Highlights From 2024 and What to Expect in 2025 — The Consumer Finance Podcast
On June 17, 2025, the U.S. Senate passed S. 1582 (GENIUS Act) with bipartisan support (68–30), creating the first comprehensive federal framework for stablecoin regulation. This landmark legislation establishes clear...more
The first 100 days of the Trump administration have included dramatic changes at the Consumer Financial Protection Bureau. The agency has retreated from many of its enforcement litigations, initiated reductions in force...more
Oregon may become the latest state attempting to stop out-of-state banks from “exporting” home-state interest rates on loans made to Oregon consumers. Like similar legislation adopted by Colorado in 2023, House Bill 2561...more
On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule (Rule) on personal financial data rights under Section 1033 of the Dodd-Frank Act. The Rule imposes significant new obligations on...more
On November 21, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule that deems payment app providers “larger participants” subject to the agency’s direct supervision (Rule)....more
The Situation: On September 17, 2024, the Federal Deposit Insurance Corporation ("FDIC") approved a proposed rule ("the Proposal") that would establish new recordkeeping requirements for FDIC-insured depository institutions...more
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
In a proposed rule and information request, the Federal Deposit Insurance Corporation expressed its concerns with the current brokered deposit restrictions and reporting requirements. Our Financial Services Team zeroes in on...more
On March 12, 2024, Acting Comptroller of the Currency Michael Hsu indicated in a speech that regulations may soon be forthcoming that would be designed to bolster larger depository institutions’ ability to withstand...more
On February 12, ten Rhode Island senators introduced S 2275, a bill proposing to opt Rhode Island out of §§ 521-523 of the Depository Institutions Deregulation and Monetary Control Act (DIDMCA). On February 13, HF 3680 was...more
Bills have been introduced in the U.S. House of Representatives (H.R. 4198) and the U.S. Senate (S. 3502) to amend the Fair Credit Reporting Act (FCRA) to curtail the practice of trigger leads with mortgage loans....more
On March 10, 2023 the California Department of Financial Protection and Innovation ("CDFPI") closed Silicon Valley Bank ("SVB"), a California chartered, non-member bank. The CDFPI placed SVB into receivership and appointed...more
The Senate Banking Committee is scheduled to mark up a new version of the SAFE Banking Act, now known as the “Secure And Fair Enforcement Regulation Banking Act” or the SAFER Banking Act (SB 2860). The revised bill addresses...more
On July 12, U.S. Senators Cynthia Lummis (R-WY) and Kirsten Gillibrand (D-NY) reintroduced legislation, titled the Responsible Financial Innovation Act that would establish a comprehensive regulatory framework for crypto...more
Now is the Time to Guard Against Reckless Banking Legislation - “Only a structural change to the way Congress acts on financial regulation will prevent future losses.” Why this is important: An old adage is that...more
An old adage is that history will repeat itself. In other words, all of this has happened before, and it will all happen again. Another banking crisis is upon us following the familiar cycle of financial deregulation. The...more
The U.S. Senate Committee on Banking, Housing, and Urban Affairs held a hearing on the following nominations: The Honorable Michael S. Barr, of Michigan, to be a Member and Vice Chairman for Supervision of the Board of...more
In This Issue. Several federal financial regulatory agencies updated their Spring 2021 regulatory agendas; the Consumer Financial Protection Bureau (CFPB) announced its intention to restart Military Lending Act examinations;...more
The OCC, the Federal Reserve Bank, and the FDIC (collectively, the Banking Regulators) announced an interim final rule on March 9 that revises their capital rules to facilitate implementation of the US Treasury Department’s...more
In the latest chapter of the ongoing saga of the U.S. Senate’s consideration and hopeful passage of the Secure and Fair Enforcement (SAFE) Banking Act, on February 7, 2020, the Credit Union National Association (CUNA) sent a...more
On 2 December 2016, the Office of the Comptroller of the Currency (“OCC”) in the U.S. announced its intention to take applications from fintech companies that wish to obtain a special purpose national bank charter (“The...more
Final TLAC Rules and Structured Products - On December 15, 2016, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued its final rules regarding long-term debt and total loss absorbing...more