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Hogan Lovells

PSD3 Impacts - September 2025

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1. Introduction - Given the sea change of PSD2, one might expect the prospect of the proposed PSD3 and PSR to have PSPs groaning at the thought of yet more root and branch reg change projects. However, whilst the proposals...more

Troutman Pepper Locke

CFPB Industry Impact Uncertain Amid Priority Shift, Staff Cuts

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On April 16, the Consumer Financial Protection Bureau released a memo to staff outlining its new supervision and enforcement priorities for 2025. These priorities appear to be intended to reverse some of the more prominent...more

Troutman Pepper Locke

FDIC Updates Consumer Compliance Examination Manual to Eliminate Disparate Impact Analysis in Response to President Trump’s...

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On August 29, the Federal Deposit Insurance Corporation (FDIC) announced updates to its Consumer Compliance Examination Manual, marking a pivotal shift in how potential discrimination under the Equal Credit Opportunity Act...more

Davis Wright Tremaine LLP

FDIC Proposes Adding Flexibility to Official Sign and Advertising Requirements

On August 21, 2025, the Federal Deposit Insurance Corporation (FDIC) published a proposed rule with several key changes to its FDIC Official Sign and Advertising Rule, only two years after it adopted requirements that were...more

Troutman Pepper Locke

Louisiana Becomes Latest State to Pass EWA Legislation

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Louisiana has enacted a new Earned Wage Access (EWA) law, effective August 1, 2025. Sponsored by Representative Vinney St. Blanc, HB 368 introduces a comprehensive compliance framework for EWA providers, marking a pivotal...more

GeoDataVision

The Regulatory Compliance Ping Pong Game

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Regulatory Compliance has been an ever-evolving process for decades. But at least the changes have been mostly steady and slow. But during the last 15 years the pace of regulatory change has not only accelerated, but it’s...more

Latham & Watkins LLP

Recent Developments for UK PLCs - September 2025

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On 7 August 2025, the FCA published its review of share buybacks in UK listed equities, which analysed data on share buybacks executed for FTSE 350 issuers, as well as feedback from banks, issuers, investor representatives,...more

A&O Shearman

Regulatory Monitoring - August 2025

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Our monthly regulatory newsletter monitors all relevant developments regarding German and European regulatory law in English language. BMF: Draft bill for the Banking Directive Implementation and Bureaucracy Relief Act...more

Orrick, Herrington & Sutcliffe LLP

OCC terminates 2022 consent order against federally chartered digital asset bank

On August 18, the OCC terminated its 2022 consent order against a federally chartered bank specializing in digital assets. The OCC, in support of its decision, cited the safety and soundness of the bank and its compliance...more

Orrick, Herrington & Sutcliffe LLP

Attorneys general urge including a safe harbor provision in the SAFER Banking Act

Recently, U.S. attorneys general from 32 states and territories authored a bipartisan letter urging Congress to advance the SAFER Banking Act of 2025, which would increase access to regulated banking and financial services...more

Orrick, Herrington & Sutcliffe LLP

FDIC releases its banking profile for Q2 of 2025

On August 26, the FDIC released its Second Quarter 2025 Quarterly Banking Profile for FDIC-insured institutions, reporting aggregate net income of $69.9 billion in the second quarter of 2025, a decrease of $677.3 million (1...more

Orrick, Herrington & Sutcliffe LLP

FDIC’s Hill outlines fall policy priorities, including GENIUS Act implementation and stablecoin oversight

On August 26, FDIC Acting Chairman Travis Hill spoke at a press conference to outline the agency’s policy agenda for the fall, highlighting implementation of the newly enacted GENIUS Act as a top priority. Hill noted that the...more

Orrick, Herrington & Sutcliffe LLP

Court orders bank to produce third-party records in prepaid debit card fees suit

On August 21, a federal magistrate judge in the District Court for the Western District of Washington ordered a bank to produce certain records related to its prepaid debit card program, including documents maintained by...more

Troutman Pepper Locke

SBA Orders Small Business Lenders to End Debanking Practices Pursuant to President Trump’s Executive Order

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On August 26, the U.S. Small Business Administration (SBA) took action to enforce President Trump’s directive by issuing a letter to its network of over 5,000 lenders. This letter mandates the cessation of alleged politicized...more

Ballard Spahr LLP

CFPB drops probe of Credova Financial LLC, saying it was politically motivated ‘debanking’

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Contending that the Biden Administration’s investigation of Credova Financial LLC was an instance of politically motivated debanking, the CFPB is dropping its probe of the company....more

Ballard Spahr LLP

32 Attorneys General call for enactment of marijuana banking legislation

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Thirty-two attorneys general representing states, territories and Washington, D.C. are asking Congress to pass legislation to provide financial institutions a safe harbor if they provide services to marijuana-related...more

Ankura

Banking Industry Outlook: U.S. Banking M&A Activity Mid-Year Review

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Active First Half: The first half of 2025 saw 72 U.S. banking mergers and acquisitions (M&A) transactions announced, representing a combined deal value of $10.39 billion....more

Orrick, Herrington & Sutcliffe LLP

States Prepare to Increase Oversight as Federal Enforcement Shifts

As federal enforcement priorities shift under a second Trump Administration, state regulators and Attorneys General appear to be stepping up their oversight efforts over consumer financial services activities. With expanded...more

Ballard Spahr LLP

Plaintiffs ask for delay in compliance dates for CFPB open banking rule

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The banking plaintiffs in the suit challenging the CFPB’s open banking rule (“Rule”) have asked a federal court to delay the compliance date of the Rule, contending that even though the Trump Administration has said it was...more

Ballard Spahr LLP

Is There Legal Authority for Trump’s “Debanking” Executive Order?

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As we previously reported, on August 7, 2025, President Trump issued an Executive Order (the “EO”) titled “Guaranteeing Fair Banking for All Americans” which, among other things...more

Skadden, Arps, Slate, Meagher & Flom LLP

Executive Order Targets Debanking and Calls for Review of Financial Institution Practices

- What is new: President Trump has signed an executive order targeting “debanking.” - Why it matters: The executive order represents a significant escalation and increased enforcement risk to financial institutions due to...more

Ballard Spahr LLP

Trump issues Executive Order prohibiting ‘debanking’

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President Trump has issued an Executive Order directing banking agencies to adopt policies to ensure that financial institutions do not use reputational risk as a basis for restricting access to banking services—a process...more

A&O Shearman

UK FPC finalises O-SII buffer framework review

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The Bank of England (BoE) has published the Financial Policy Committee's (FPC) final response to the 2024 review of the Other Systemically Important Institutions (O-SII) buffer framework. This follows the March consultation,...more

A&O Shearman

BoE consults on extending RT2 and CHAPS settlement hours – Phase 1

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The Bank of England (BoE) has published a consultation paper outlining Phase 1 of its extension to settlement hours for the UK's renewed Real-Time Gross Settlement system (RT2) and CHAPS. RT2 went live in April. The BoE has...more

Hogan Lovells

Bank of England consults on longer RTGS and CHAPS operating hours

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The Bank of England (the “Bank”) published a consultation paper (“CP”) on 29 July 2025 on proposals to extend Real-Time Gross Settlement (“RTGS”) and CHAPS operating hours. The CP follows the Bank’s 2024 discussion paper on...more

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