On September 4, the CFPB published its Spring 2025 Unified Agenda on the Office of Information and Regulatory Affair’s website. The agenda identifies 24 regulatory items across the final, proposed, and prerule stages, covering a wide range of consumer finance issues.Continue Reading CFPB Releases Spring 2025 Agenda Signaling Deregulatory Shift
On August 26, 2025, the CFPB published a notice of proposed rulemaking to narrow the scope of its authority to designate nonbanks for supervision under the Consumer Financial Protection Act (CFPA). The proposal follows earlier announcements by the Bureau that it would reassess its use of this authority (previously discussed here).Continue Reading CFPB Proposes Rule Narrowing Nonbank Supervisory Authority Under CFPA
On August 21, the Consumer Financial Protection Bureau published an advance notice of proposed rulemaking (ANPR) in the Federal Register to reconsider its Personal Financial Data Rights Rule under Section 1033 of the Dodd-Frank Act. The Bureau stated that it is reopening the rule in light of policy changes under new leadership and a court-ordered stay in ongoing litigation challenging the 2024 final rule.Continue Reading CFPB Reopens Data Rights Debate with New 1033 Rulemaking
Four advance notices of proposed rulemaking scheduled for publication on August 8 will solicit public comment on whether the CFPB should raise the size thresholds that determine which nonbank entities qualify as “larger participants” subject to routine Bureau supervision. The notices address the automobile-financing, international money-transfer, consumer-reporting, and consumer debt-collection markets. Continue Reading CFPB Seeks Comment on Proposed Rules to Scale Back Larger Participant Thresholds
On August 4, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a notice warning financial institutions about escalating illicit activity involving convertible virtual currency (CVC) kiosks. The notice cites increased misuse of CVC kiosks in fraud schemes, drug trafficking, and cybercrime, and identifies operators’ potential violations of the Bank Secrecy Act (BSA) through failures to register, implement anti-money laundering (AML) programs, or conduct customer due diligence.Continue Reading FinCEN Warns Financial Institutions of Illicit Activity at Crypto Kiosks
On July 29, the U.S. District Court for the Eastern District of Kentucky granted the CFPB’s request to stay litigation challenging its open banking rule. The rule (previously discussed here) aimed to establish industry-wide standards for data access and sharing between banks, fintechs, and consumers. The Bureau stated that it intends to revise the rule through an accelerated rulemaking process.Continue Reading In a Surprising Switch, CFPB Now Seeks to Rewrite Open Banking Rule
On July 18, the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS ACT) was signed into law, creating the first federal regulatory framework for payment stablecoins. The law prohibits the issuance of payment stablecoins in the United States unless the issuer is a permitted entity under a state or federal regime that meets strict reserve, redemption, compliance, and disclosure requirements.Continue Reading Stablecoin Regulation Takes Effect Under Newly Enacted GENIUS Act
On July 11, the U.S. District Court for the Eastern District of Texas vacated the CFPB’s Medical Debt Rule, concluding that the rule exceeded the Bureau’s statutory authority under the Fair Credit Reporting Act (FCRA). The decision blocks a major regulatory effort aimed at limiting the role of medical debt in credit underwriting. The CFPB’s now-vacated rule also would have barred lenders from considering medical debt when evaluating loan applications.Continue Reading Texas Court Vacates CFPB Medical Debt Reporting Rule
On July 14, the OCC, Federal Reserve, and FDIC announced the release of a joint statement clarifying how existing laws and regulations apply to crypto-asset safekeeping services offered by banking organizations. The statement does not impose new supervisory expectations but reinforces how banking organizations must apply established fiduciary duties, risk management standards, and third-party oversight frameworks when holding crypto-assets on behalf of customers.Continue Reading Federal Banking Regulators Issue Joint Guidance on Crypto-Asset Safekeeping
On June 23, the Federal Reserve Board announced that reputational risk will no longer be a component of its bank-examination program. The same day, the Board released a revised edition of its Guidelines for Rating Risk Management at State Member Banks and Bank Holding Companies, which deletes every reference to reputational risk.Continue Reading Federal Reserve Board Removes Reputational Risk from Examination Ratings