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A.J. is a partner in the Finance and Bankruptcy Practice Group in the firm's Washington, D.C. office.

The CFPB is extending the comment periods for two proposed rulemakings under Regulation V, which implements the Fair Credit Reporting Act (FCRA). On March 5, the Bureau extended the comment period for its proposed rule on data brokers and consumer reports. Similarly, on March 7, the CFPB announced an extension for its Advance Notice of Proposed Rulemaking (ANPR) on identity theft and coerced debt.Continue Reading CFPB Extends Comment Periods for Two Proposed Regulation V Rules

On March 3, Massachusetts Attorney General Andrea Joy Campbell announced new regulations, issued under the Massachusetts Consumer Protection Act, aimed at curbing “junk fees” by requiring businesses to disclose total prices upfront and provide clear information about additional charges. The regulations, set to take effect September 2, 2025, seek to prevent deceptive pricing practices and enhance consumer transparency.Continue Reading Massachusetts AG Issues New Regulations Targeting Junk Fees 

On March 7, the OCC issued Interpretive Letter 1183 and an accompanying statement affirming prior guidance regarding whether national banks and federal savings associations may engage in cryptocurrency-related activities, including (i) providing custody services for depositors’ crypto assets, (ii) holding stablecoin “reserves,” (iii) facilitating stablecoin payments, and (iv) performing payment verification activities on blockchain networks. Importantly, the letter also rescinded the OCC’s Interpretive Letter 1179, which required banks to obtain written supervisory non-objection before engaging in these cryptocurrency activities.Continue Reading OCC Clarifies Banks’ Role in Cryptocurrency Activities

On March 10, 2025, the CFPB informed the U.S. District Court for the Northern District of Texas that it will proceed with litigation against a short-term installment lender and its subsidiary for alleged violations of the Military Lending Act (MLA). The lawsuit alleges that the lender violated the MLA and a 2013 administrative consent order by issuing loans to military service members with interest rates exceeding the MLA’s 36% cap, included mandatory arbitration provisions in loan contracts, and failed to provide required disclosures. The CFPB further asserts that these practices continued despite a prior CFPB enforcement order against the lender’s predecessor.Continue Reading CFPB Moves Forward with Military Lending Act Enforcement Against Installment Lender 

The CFPB is facing pushback from the U.S. Senate over two final rules issued under the Biden administration: one expanding oversight of nonbank digital payment providers and another limiting the reporting of medical debt. Both efforts invoke the Congressional Review Act (CRA), a legislative mechanism that allows Congress to roll back recently finalized federal regulations.Continue Reading GOP Senators Moving to Invoke the Congressional Review Act Over Biden-Era Rules

On March 1, and despite recent policy shifts under the new administration, the CFPB sent a letter to the judge overseeing its lawsuit against a fintech lender in the United States District Court for the Southern District of New York, stating that it would proceed with its filed action. The lawsuit, originally filed in September 2022, alleges violations of the Military Lending Act’s (MLA) restrictions on extensions of credit to covered servicemembers. The complaint further alleges violations of the Consumer Financial Protection Act’s (CFPA) prohibitions on unfair, deceptive, or abusive acts or practices (UDAAPs). Continue Reading CFPB Continues Lawsuit Over Alleged Military Lending Act Violations

On March 3, the FDIC announced the withdrawal of its proposed rule on brokered deposits, citing concerns regarding potential disruptions to the financial sector. This move follows significant pushback from industry stakeholders who argued that the proposed changes could have unintended consequences for liquidity management and market stability.Continue Reading FDIC Withdraws Proposed Rule on Brokered Deposits

On February 18, the Maryland Office of Financial Regulation (OFR) issued an alert to address industry concerns regarding its January guidance on licensing requirements for assignees of residential mortgage and installment loans. In response to market pushback, the OFR has proposed new legislation to exempt certain entities from licensing requirements and has extended the enforcement deadline to allow for further regulatory clarity.Continue Reading Maryland OFR Responds to Market Concerns Over Licensing Requirements for Mortgage and Installment Loan Assignees