News & Analysis as of

Financial Services Industry Enforcement Actions

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

FINRA fines broker-dealer $500K for failure to file suspicious activity reports

On August 22, FINRA accepted a Letter of Acceptance, Waiver, and Consent (AWC) from a broker-dealer member firm regarding its alleged failure to establish and implement policies and procedures designed to detect suspicious...more

Orrick, Herrington & Sutcliffe LLP

Massachusetts state court allows consumer protection suit over home equity investment product to proceed

On August 21, a Massachusetts superior court denied a motion to dismiss filed by a financial technology company offering a home equity investment (HEI) product. The financial technology company asserted that the HEI is an...more

Ballard Spahr LLP

SBA directs financial institutions to end, correct debanking actions

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Citing President Trump’s Executive Order, the SBA has sent letters to its network of more than 5,000 lenders instructing them to end what the Trump Administration said is politicized or unlawful debanking....more

Troutman Pepper Locke

Illinois Amends Student Loan Servicing Rights Act to Include Educational Income Share Agreements

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On August 15, Illinois Governor JB Pritzker approved Public Act 104-0383. This legislation, effective immediately, amends the Student Loan Servicing Rights Act and introduces Article 7, focusing on Educational Income Share...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 files complaint against Synapse Financial Technologies

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The CFPB has filed a complaint against Synapse Financial Technologies Inc, alleging that the company engaged in unfair acts and practices in violation of the Section 1036(a)(1)(B) of the CFPA by failing to maintain sufficient...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

Kelley Drye & Warren LLP

Ad Law News and Views - August 2025

Last week, Missouri Attorney General Andrew Bailey announced his resignation from the position effective September 8. He issued a press release reporting that he is leaving to serve as the Co-Deputy Director of the FBI, in...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – August 3, 2025

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more

A&O Shearman

First DOJ Declination For FCPA Violations Since Renewed Enforcement Guidelines

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On August 7, 2025, the United States Department of Justice, Criminal Division, Fraud Section (“DOJ”) issued a declination letter to a U.S.-based insurance company (the “Company”) to resolve alleged violations of the Foreign...more

A&O Shearman

SEC Appoints Judge Margaret “Meg” Ryan as the New Director of the Division of Enforcement

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The Securities and Exchange Commission (“SEC”) has named Judge Margaret “Meg” Ryan as the new Director of the Division of Enforcement. Judge Ryan will succeed Acting Director Sam Waldon, who has served as Acting Director of...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

Guidepost Solutions LLC

High-Risk Enforcement Areas for Financial Services Providers: AI, Lending, and Privacy

Did you know that U.S. federal regulators issued approximately 173 public enforcement actions against financial services providers in 2024? Over 35% of those enforcement actions resulted in some form of monetary penalty,...more

DLA Piper

SEC Establishes AI Task Force to Drive Internal Innovation and Efficiency

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The US Securities and Exchange Commission (SEC) has announced the formation of a dedicated Artificial Intelligence (AI) Task Force, marking a significant step in the agency’s ongoing efforts to modernize its operations and...more

A&O Shearman

UK FCA issues updated Enforcement Information Guide

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The UK Financial Conduct Authority published an updated Enforcement Information Guide, which reflects changes in the FCA Handbook to its revised Enforcement Guide (ENFG) and the Decision Procedure and Penalties manual (DEPP)....more

Orrick, Herrington & Sutcliffe LLP

NYDFS announces $48.5M settlement over anti-money laundering deficiencies

NYDFS Superintendent Harris announced a $48.5 million settlement with a virtual currency trust company on August 7, resolving allegations of anti-money laundering program deficiencies and failures in due diligence related to...more

Venable LLP

Chalk Talk: Are Sports Prediction Markets Just Unregulated Gambling in Disguise?

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Welcome to Chalk Talk, your legal playbook for the ever-evolving sports industry. Each month, our Sports Law team will draw up the X's and O's behind the legal, policy, and regulatory issues impacting your business. We'll...more

Kelley Drye & Warren LLP

NY AG Zeroes in on Zelle with Lawsuit

Last week, New York Attorney General Letitia James announced a lawsuit against Early Warning Services LLC (EWS), the parent company of digital payment network Zelle. AG James asserts that Zelle was designed ​“without critical...more

Sheppard Mullin Richter & Hampton LLP

Trump Signs Executive Order on Debanking

On August 7, President Trump signed an Executive Order directing federal banking regulators to prevent financial institutions and financial service providers from denying or restricting financial services and products based...more

McGlinchey Stafford

[Webinar] Deep Dive into Lending: Unsecured Lending - August 26th, 10:00 am PT

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Unsecured lending remains a dynamic, fast-evolving segment of the consumer finance market — drawing increasing attention from regulators, litigators, and market participants alike. In this next installment of our Deep Dives...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

Mintz

Trump Executive Order Attacks "De-banking" Practices

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On August 7, 2025, President Trump issued an executive order targeting the practice of de-banking--as described in the executive order, actions to “restrict law-abiding individuals' and business' access to financial services...more

DLA Piper

“Fair Banking” Executive Order Targets Politicized Debanking and Reputational Risk

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On August 7, 2025, President Donald Trump issued an Executive Order entitled “Guaranteeing Fair Banking for all Americans” (EO). The EO broadly prohibits banks and other financial institutions from engaging in “politicized or...more

Troutman Pepper Locke

FINRA Continues to Scrutinize Customer Facing Communications on Crypto Offerings

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On July 16, TradeStation Securities, Inc., a member firm of the Financial Industry Regulatory Authority (FINRA), submitted a Letter of Acceptance, Waiver, and Consent (AWC) to FINRA’s Department of Enforcement. This AWC...more

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