On April 11, the CFPB announced that it will not prioritize enforcement or supervision against nonbank financial companies that miss registration deadlines under its Repeat Offender Registry. The Bureau also stated that it is considering a notice of proposed rulemaking to rescind or narrow the scope of the rule, finalized in 2024, that established the registry.Continue Reading CFPB Announces It Will Not Prioritize Oversight of Repeat Offender Registry
On April 4, the California Department of Financial Protection and Innovation (DFPI) issued proposed regulations under the Digital Financial Assets Law (DFAL). The proposal provides clarification on DFAL’s licensing framework and identifies when digital asset activity may qualify for exemptions under California’s Money Transmission Act.Continue Reading California DFPI Proposes Digital Asset Licensing Rule
On March 21, the U.S. Department of the Treasury submitted a report to the Office of Management and Budget affirming that all 11 programs administered by the Community Development Financial Institutions (CDFI) Fund are required by law. The report includes citations to the specific statutory authorities underlying each program.Continue Reading Treasury Confirms All CDFI Fund Programs Are Backed by Law Amid Executive Order Review
Utah and Arkansas have enacted new legislation governing earned wage access (EWA) services, establishing state-level registration obligations and consumer protection standards. Both laws clarify that EWA services are not loans under state law if certain conditions are met, including limitations on fees, debt collection, and credit reporting.Continue Reading Utah and Arkansas Enact Earned Wage Access Regulations
On March 28, the FDIC issued updated guidance clarifying the process for FDIC-supervised institutions to engage in crypto-related activities. The guidance rescinds and replaces prior instructions issued in 2022 and makes clear that banks no longer need to seek prior FDIC approval before participating in permissible crypto activities.Continue Reading FDIC Updates Crypto Guidance, Removes Pre-Approval Requirement for Banks
On March 28, the Federal Reserve, FDIC, and OCC jointly announced plans to rescind 2023 revisions to the Community Reinvestment Act (CRA) regulations. The agencies stated they would return to the previous regulatory framework existing before the 2023 revisions (See our prior discussion here).Continue Reading Federal Regulators Signal Reversal on 2023 CRA Modernization Rule
On March 13, New York Attorney General Letitia James announced the introduction of the Fostering Affordability and Integrity through Reasonable Business Practices Act (FAIR Business Practices Act). The proposed legislation seeks to extend the state’s existing ban on deceptive business practices to also prohibit unfair and abusive practices, aligning New York with 42 other states. Continue Reading New York Attorney General Proposes Bill to Expand Consumer Protection Law
In a March 10 blog post, the new Director of the FTC’s Bureau of Consumer Protection (BCP) reaffirmed the agency’s commitment to enforcing consumer protection laws through Civil Investigation Demands (CIDs). Continue Reading FTC Signals Strong Stance on Civil Investigation Demands
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 4, the California DFPI finalized regulations under the Debt Collection Licensing Act (DCLA). The final regulations, which take effect July 1, 2025, clarify key licensing and reporting requirements.Continue Reading DFPI Finalizes Debt Collection Licensing Regulations, Effective July 1