On September 23, the Massachusetts Division of Banks finalized amendments to the Small Loans Law, the Truth in Lending Act, and the Mortgage Lender and Broker Licensing Law. The changes update licensing procedures, disclosure rules, and financial-responsibility standards for financial institutions operating in Massachusetts. The amendments introduce new requirements affecting application reviews, notice obligations, and... Continue Reading|
On September 18, the OCC announced its monthly enforcement actions for September, which included the termination of a 2023 consent order against a national bank and the termination of a 2020 consent order against a federal savings association. Both terminations followed earlier OCC findings of unsafe or unsound practices and alleged violations of federal banking... Continue Reading|
On September 23, 2025, the California Privacy Protection Agency (CPPA) announced that the California Office of Administrative Law approved final regulations under the California Consumer Privacy Act (CCPA). The regulations (previously discussed here) cover cybersecurity audits, risk assessments, automated decision making technology (ADMT), insurance companies, and updates to existing CCPA obligations. The regulations require annual... Continue Reading|
On September 22, 2025, the CFPB terminated two consent orders, one involving a national bank and the other involving a mortgage servicer. The orders were originally issued under prior administrations and alleged violations of the Home Mortgage Disclosure Act (HMDA), the Consumer Financial Protection Act (CFPA), the Real Estate Settlement Procedures Act (RESPA), and the Fair... Continue Reading|
On September 25, the CFPB finalized a rule rescinding its several Biden-era amendments to the risk-based supervisory designation process and reinstating the Bureau’s 2013 framework under the Dodd-Frank Act. The rule, effective October 27, restores confidentiality of decisions and orders, revives the role of a recommending official, and eliminates several procedural changes made in 2022-2024. Under... Continue Reading|
On September 17, the New York Department of Financial Services (NYDFS) issued a notice advising all state-chartered banks, credit unions, and foreign bank branches licensed in New York to consider integrating blockchain analytics into their compliance and risk frameworks when engaging in virtual currency-related activity. The notice builds on the Department’s 2022 blockchain analytics guidance... Continue Reading|
On September 16, Oregon Governor Tina Kotek announced three consumer protection laws: Senate Bill 605 on medical-debt credit reporting, House Bill 3178 on auto sales and financing disclosures, and Senate Bill 430 on online pricing transparency. All three bills take effect in 2026. SB 605 prohibits reporting the amount or existence of medical debt to... Continue Reading|
On September 22, the Financial Crimes Enforcement Network proposed to delay the effective date of its Investment Adviser/CFT Program and SAR requirements| Consumer Finance and Fintech Blog
On July 1, the CFPB terminated two separate consent orders, one involving a federal credit union and the other involving a national mortgage| Consumer Finance and Fintech Blog
On June 2, the U.S. District Court for the Eastern District of Pennsylvania terminated a 2022 consent order and dismissed with prejudice the CFPB and| Consumer Finance and Fintech Blog
On September 11, the Federal Trade Commission announced final orders permanently banning two individual defendants from the debt relief industry and imposing asset surrender provisions to resolve allegations of a fraudulent student loan forgiveness scheme. The FTC alleged violations of the Federal Trade Commission Act, the Telemarketing Sales Rule, the Gramm-Leach-Bliley Act, and the FTC’s new... Continue Reading|
On September 12, the U.S. District Court for the Eastern District of Kentucky upheld the Federal Reserve Board’s Regulation II cap on debit-card interchange fees, rejecting a merchant’s Administrative Procedure Act challenge. The court concluded the rule is neither “contrary to law” nor “arbitrary and capricious,” interpreting the Dodd-Frank Act’s Durbin Amendment under the Electronic... Continue Reading|
On August 18, the OCC terminated its 2022 consent order against a national bank. The order was issued under the Bank Secrecy Act and related anti-money| Consumer Finance and Fintech Blog
On August 19, 2025, the CFPB announced that it had closed a multi-year investigation into a fintech company offering buy-now, pay-later financing for| Consumer Finance and Fintech Blog
On May 20, the U.S. Senate voted 66-32 to move forward with the Guardrails and Enforcement for Neutral Issuers of United States Stablecoins (GENIUS) Act| Consumer Finance and Fintech Blog
On July 30, 2025, the President's Working Group on Digital Asset Markets released a comprehensive report recommending substantial regulatory action and| Consumer Finance and Fintech Blog
On August 12, a coalition of banking trade associations sent a joint letter to Congress warning that the recently enacted GENIUS Act contains a loophole| Consumer Finance and Fintech Blog
On August 4, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a notice warning financial institutions about escalating illicit activity| Consumer Finance and Fintech Blog
On July 18, the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS ACT) was signed into law, creating the first federal| Consumer Finance and Fintech Blog
On July 18, the CFPB terminated a 2024 consent order against a credit union after concluding that the entity had satisfied certain monetary and| Consumer Finance and Fintech Blog
On July 11, 2025, the Consumer Financial Protection Bureau (CFPB) announced a proposed $9 million settlement resolving its November 2021 lawsuit against a| Consumer Finance and Fintech Blog
On May 7, the OCC issued Interpretive Letter 1184, reaffirming that national banks and federal savings associations may provide cryptocurrency custody and| Consumer Finance and Fintech Blog
On July 14, the OCC, Federal Reserve, and FDIC announced the release of a joint statement clarifying how existing laws and regulations apply to| Consumer Finance and Fintech Blog
On June 24, the Department of Housing and Urban Development (HUD) issued a Request for Information (RFI) to evaluate how Buy Now Pay Later (BNPL) loans| Consumer Finance and Fintech Blog
On March 7, the OCC issued Interpretive Letter 1183 and an accompanying statement affirming prior guidance regarding whether national banks and federal| Consumer Finance and Fintech Blog
Just over one month into the second Trump Administration, the crypto industry appears poised to notch yet another victory in its longstanding tug-of-war| Consumer Finance and Fintech Blog
On March 18, Acting Comptroller of the Currency Rodney Hood reiterated the OCC’s commitment to ensuring fair access to banking services, including for| Consumer Finance and Fintech Blog
On December 12, the CFPB released the final version of its overdraft rule that was first proposed in January. (We discussed it here.) Currently, financial| Consumer Finance and Fintech Blog
On January 26, the California DFPI announced its participation in a $22.5MM multi-state into a settlement with a with a Cayman Islands digital asset firm| Consumer Finance and Fintech Blog
On November 22, the CFPB denied a crypto lending institution’s petition for an order modifying a pending civil investigative demand (“CID”) that the| Consumer Finance and Fintech Blog
On October 19, in Community Financial Services Association of America, Limited v. Consumer Financial Protection Bureau, a three-judge panel in the Fifth| Consumer Finance and Fintech Blog
On July 6, the CFPB posted a blog titled, “Should you buy now and pay later?” describing how buy now pay later (BNPL) deferred payment options work, and| Consumer Finance and Fintech Blog
On October 26, the United States District Court for the Southern District of Texas issued a nationwide preliminary injunction barring the CFPB from moving| Consumer Finance and Fintech Blog
On July 22, a Texas-based lease-to-own company filed suit against the CFPB in Federal District Court for the Eastern District of Texas alleging that its| Consumer Finance and Fintech Blog
On May 22, the CFPB announced an interpretive rule confirming that Buy Now, Pay Later (BNPL) lenders qualify as credit card providers under the Truth in| Consumer Finance and Fintech Blog
On December 16, the CFPB issued a series of orders to five companies offering “buy now, pay later” (BNPL) credit. The orders seek to collect information| Consumer Finance and Fintech Blog
On March 21, Wisconsin enacted into law Assembly Bill 574, positioning it as the third state, following Nevada and Missouri, to establish a comprehensive| Consumer Finance and Fintech Blog
On December 18, the Arizona Attorney General issued an opinion on earned wage access (EWA), which determined that fully non-recourse EWA products do not| Consumer Finance and Fintech Blog
