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On December 30, the U.S. District Court for the District of Columbia ordered that the CFPB must continue requesting funding from the Board of Governors of the Federal Reserve System under the statutory funding framework established by Congress. The Court ruled that the CFPB may not decline to request funding based on its interpretation of the Federal Reserve’s operating losses or an asserted lack of available “combined earnings.” (previously discussed here).Continue Reading Federal Court Orders CFPB to Continue Requesting Funding Operations Amid Defunding Dispute

On December 15, the Board of Governors of the Federal Reserve System and the CFPB issued joint final rules amending the official interpretations to their regulations implementing the Consumer Leasing Act and the Truth in Lending Act. The amendments reflect the annual inflation adjustment required by statute and increase the exemption thresholds effective January 1, 2026.Continue Reading CFPB and Federal Reserve Finalize 2026 Inflation Adjustments to Consumer Leasing and Truth in Lending Coverage Thresholds

On December 1, 2025, the Federal Reserve released its semiannual Supervision and Regulation Report describing a broad reduction in outstanding supervisory findings across institutions of all sizes. The report indicates declines among global systemically important banks, large foreign and domestic banking organizations, and small and midsize banks, reflecting a shift in the Fed’s supervisory posture.Continue Reading Federal Reserve Reports Decline in Open Supervisory Findings Across All Bank Portfolios

On November 11, 2025, the Department of Justice intervened in the Consumer Financial Protection Bureau’s dispute with its employee union and notified the D.C. Circuit that the Bureau’s funding structure was unconstitutional and it can no longer draw funds from the Federal Reserve to fund its operations. The filing cited a formal opinion from the Department of Justice’s Office of Legal Counsel concluding that the Federal Reserve currently lacks “combined earnings” from which the Bureau may lawfully obtain funding. Previously, the Bureau stated that it could draw funds from the Federal Reserve’s revenues, but now maintains that only profits, not revenues, qualify as “combined earnings” under the Dodd-Frank Act. Because the Federal Reserve has been operating at a loss since 2022, there are currently no profits available for transfer to the CFPB. The OLC opinion states that the only way for the CFPB to keep the lights on is to request appropriations from Congress.Continue Reading CFPB Says its Funding Structure is Unconstitutional but a New Bureau Director is Nominated

On October 16, Federal Reserve Governor Michael Barr delivered remarks highlighting the significant implementation gaps regulators must bridge under the GENIUS Act, the newly enacted federal framework for payment stablecoins (previously discussed here). Barr’s comments centered on areas where the statute leaves critical details to regulators, including reserve composition, supervisory authority, and consumer safeguards, which will determine whether the framework effectively mitigates systemic and operational risks.Continue Reading Federal Reserve Governor Barr Highlights Gaps Regulators Must Bridge Under GENIUS Act

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 Fund Transfer Act to permit consideration of certain transaction-related costs when setting the cap.Continue Reading Kentucky Federal Court Upholds Federal Reserve’s Debit-Card Fee Cap

On August 15, the Federal Reserve Board announced that it has rescinded its 2023 supervisory letter establishing the Novel Activities Supervision Program (NASP). The program had focused on overseeing banks’ involvement in crypto assets, distributed ledger technology, and fintech partnerships. The Fed explained that it has “strengthened its understanding” of these activities and will return to supervising them through the standard supervisory process.Continue Reading Federal Reserve Ends Novel Activities Supervision Program for Crypto and Fintech Oversight

On August 6, the U.S. District Court for the District of North Dakota vacated the Federal Reserve’s 2011 Regulation II interchange fee cap rule, finding that the rule allegedly exceeded the FRB’s authority under the Durbin Amendment of the Dodd-Frank Act. The court determined that the Board improperly included costs unrelated to specific transactions in calculating the interchange fee cap.Continue Reading Federal Court Vacates Federal Reserve’s Interchange Fee Rule

On August 7, President Donald Trump announced his intent to nominate Stephen Miran, Chair of the Council of Economic Advisers, to the Federal Reserve Board of Governors. If confirmed by the Senate, Miran would replace Governor Adriana Kugler, who resigned August 8, and serve through the remainder of her term, ending January 31, 2026, while the search for a permanent replacement takes place.Continue Reading Trump to Nominate Stephen Miran to Federal Reserve Board of Governors

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