News & Analysis as of

Financial Services Industry Comment Period

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

Orrick, Herrington & Sutcliffe LLP

CFPB proposes rule clarifying supervisory designation standard for nonbanks

On August 26, the CFPB issued a proposed rule to clarify the legal standard when determining whether to designate a nonbank covered person for Bureau supervision under Section 1024(a)(1)(C) of the CFPA. The proposal would...more

Troutman Pepper Locke

CFPB Proposes Stricter Standards Limiting Supervision of Nonbanks

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The Consumer Financial Protection Bureau (CFPB or Bureau) is taking a significant step to modify its supervisory approach to nonbanks by publishing a proposed rule advancing a more stringent definition of “risks to consumers”...more

Morgan Lewis

CFPB Invites Comment on Larger Participant Thresholds

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The Consumer Financial Protection Bureau has issued advance notices of proposed rulemaking seeking public comment on whether to revise the thresholds that define “larger participants” in key consumer financial industries....more

A&O Shearman

UK Financial Ombudsman Service Funding Model Proposals

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The UK Financial Ombudsman Service (FOS) has published a consultation on further changes to its case fee structure. In April, the FOS implemented changes to its charging structure, which included charges for professional...more

Troutman Pepper Locke

CFPB Proposes Rules Re-Defining Larger Participants in Multiple Markets

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On August 8, the Consumer Financial Protection Bureau (CFPB or Bureau) published a series of proposed rules aimed at redefining what constitutes a “larger participant” in several key financial markets. Under § 1024 of the...more

Ballard Spahr LLP

CFPB Seeks Comments On Raising ‘Larger Participant’ Thresholds

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On August 8, 2025, the Consumer Financial Protection Bureau (“CFPB”) issued four advance notices of proposed rulemaking (“ANPR”) inviting comments on whether it should substantially reduce the number of nonbank companies the...more

Fisher Phillips

GLBA Set for Overhaul? 10 Questions That May Decide the Next Generation of Financial Privacy Law

Fisher Phillips on

Congress is asking the financial industry – and anyone else with a stake in consumer data – to weigh in on the future of the Gramm-Leach-Bliley Act (GLBA). On July 31, the US House Financial Services Committee leaders issued...more

Stikeman Elliott LLP

AMF Proposes Amendments to Fee Structure for Market Participants in Québec

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The Autorité des marchés financiers (“AMF”) has published for comment proposed amendments (the “Proposed Amendments”) that are intended to recalibrate and update certain fees, costs and penalties prescribed under the...more

A&O Shearman

BoE outlines proposed approach to FMI rule permissions

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The Bank of England (BoE) has published a consultation paper on a draft statement of policy (SoP) outlining its proposed approach to permissions, waivers and supervisory processes for central counterparties (CCPs), systemic...more

A&O Shearman

EC consults on draft Delegated Regulation on fees payable to ESMA following BMR review

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The European Commission has published a proposed draft Delegated Regulation on supervisory fees under the revised EU Benchmarks Regulation...more

A&O Shearman

Mansion House: HMT consultation on FOS and joint FCA and FOS consultation on modernising the financial redress system

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HM Treasury (HMT) has published a consultation paper setting out proposed reforms to the UK Financial Ombudsman Service (FOS), in tandem with the joint UK Financial Conduct Authority and FOS consultation paper (CP25/22) on...more

A&O Shearman

EBA consults on revision to POG guidelines for ESG retail banking products

A&O Shearman on

The European Banking Authority (EBA) has published a consultation paper on proposed revisions to its product oversight and governance (POG) guidelines for retail banking products. The EBA considers the update necessary in...more

Troutman Pepper Locke

Federal Banking Agencies Propose Rescission of 2023 CRA Final Rule and Reinstatement of 1995 CRA Regulations

Troutman Pepper Locke on

On July 16, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the federal banking agencies) jointly published a proposed rule...more

Orrick, Herrington & Sutcliffe LLP

Fed requests comments on its Large Financial Institution rating system

On July 15, the Fed published a notice and request for comment in the Federal Register on revisions to its Large Financial Institution (LFI) rating system and the Insurance Supervisory Framework. The rating system governs...more

Ballard Spahr LLP

CFPB proposes to rescind rule requiring nonbanks to register certain agency enforcement and court orders

Ballard Spahr LLP on

The CFPB is proposing to rescind its rule that requires certain nonbank entities to register covered agency enforcement and court orders....more

Orrick, Herrington & Sutcliffe LLP

CFPB proposes to rescind amendments to nonbank supervision

On May 14, the CFPB published a Federal Register notice withdrawing its proposed rule on the Procedures for Supervisory Designation Proceedings. These amendments were each codified in 12 C.F.R. 1091. As previously covered by...more

Troutman Pepper Locke

CFPB Proposes Rescission of Nonbank Registration Rule

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Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) released a proposed rule to rescind its previous regulation requiring nonbank entities to report certain agency and court orders to a Bureau registry....more

Ballard Spahr LLP

CFPB extends comment period for data broker NPRM

Ballard Spahr LLP on

The CFPB has extended the comment period for its Notice of Proposed Rulemaking on data brokers until April 2, 2025; the comment period had been slated to expire on March 3, 2025....more

White & Case LLP

CFPB’s Proposed Rule Aims to Prohibit the Use of Certain Contractual Provisions in Consumer Financial Products or Services...

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Background, Purpose, and Structure of the Proposed Rule - On January 13, 2025, the Consumer Financial Protection Bureau (CFPB) published a proposed rule, which aims "to prohibit certain contractual provisions in agreements...more

Troutman Pepper Locke

NYC DCWP Further Delays Effective Date of Amended Debt Collection Rules

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In our previous post, we discussed the New York City Department of Consumer and Worker Protection’s (NYC DCWP) decision to delay the enforcement of the amended debt collection rules from December 1, 2024, to April 1, 2025....more

Orrick, Herrington & Sutcliffe LLP

CFPB issues new proposal to ban certain financial contract terms

On January 13, the CFPB proposed a new rule to ban large banks and consumer finance companies from using certain contractual provisions in agreements with consumers under Regulation AA. The CFPB’s proposal warns against the...more

Orrick, Herrington & Sutcliffe LLP

CFPB seeks comments on proposed interpretive rule expanding the application of the EFTA to a wide range of digital assets

On January 10, the CFPB proposed an interpretive rule that could significantly broaden the scope of the EFTA to encompass a broad range of digital assets, including—if they meet certain requirements — cryptocurrency accounts,...more

Ballard Spahr LLP

CFPB proposes rule to ban consumer contract terms bureau says limit ‘fundamental freedom’

Ballard Spahr LLP on

The CFPB has published a proposed rule that would ban companies from using contract clauses that the bureau said limit fundamental freedom, including those that waive a consumer’s legal rights and fine print that suppresses...more

A&O Shearman

UK Financial Conduct Authority consults on a new product information framework for consumer composite investments

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The U.K. Financial Conduct Authority has published a consultation on a new product information framework for Consumer Composite Investments. The regime will apply in respect of a CCI which is or may be distributed to a retail...more

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