News & Analysis as of

Financial Institutions

Stinson LLP

CFPB and OCC Signal Strategic Shifts in Supervision and Enforcement

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In April 2025, both the Consumer Financial Protection Bureau (CFPB) and the Office of the Comptroller of the Currency (OCC) announced significant changes to their supervisory and enforcement approaches, signaling a shift in...more

Holland & Knight LLP

CFPB Credit Card Late Fees Rule Vacated by Texas District Court

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On April 15, 2025, Judge Mark T. Pittman of the U.S. District Court for the Northern District of Texas entered an order and final judgment vacating the CFPB's credit card penalty fees rule (the Late Fee Rule). Judge Pittman's...more

Lowenstein Sandler LLP

CFTC Staff Seeks Public Feedback on Perpetual Contracts and 24/7 Trading

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On April 21, 2025, the Commodity Futures Trading Commission’s (CFTC) Divisions of Market Oversight, Clearing and Risk, and Market Participants issued two requests for comments soliciting public feedback related to the...more

A&O Shearman

EPC publishes Guidelines for PSPs joining payment schemes

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The European Payments Council (EPC) has issued Version 7.0 of the Adherence Guide to the EPC Payment Schemes, together with an updated webpage. The updated guide provides guidelines and template application forms for payment...more

A&O Shearman

EBA publishes report on remuneration and gender pay gap for financial institutions

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The European Banking Authority (EBA) has issued its latest report on remuneration and gender pay gap benchmarking for institutions and investment firms, together with a press release. The report covers information on...more

Venable LLP

CFPB Narrows Supervision and Enforcement, Leaving Broader Focus to States

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The CFPB confirmed in a recent memo to staff that it is shifting its tone on supervision and enforcement—even as reports circulate about significant staffing cuts and potential structural changes at the agency. ...more

Katten Muchin Rosenman LLP

Financial Industry Concerns Cause FCC to Delay Implementation of Broad Consent Revocation Requirement under TCPA

On April 11, 2025, a controversial new rule by the Federal Communications Commission (FCC) was set to take effect to modify consent revocation requirements under the Telephone Consumer Protection Act (TCPA). But each of the...more

Ankura

Navigating the Digital Operational Resilience Act (DORA): How We Helped Indian Banks Operating in Europe

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The Digital Operational Resilience Act (DORA) is a transformative regulation introduced by the European Union to bolster the resilience of financial institutions against Information and Communication Technology (ICT) risks....more

ArentFox Schiff

The End of LIBOR: Hotel California Edition [Part IV]

ArentFox Schiff on

During the transition of the London InterBank Offered Rate (LIBOR) to the approved substitute benchmark in the United States, the Secured Overnight Financing Rate (SOFR), a basic question was raised as to whether the new...more

Allen Matkins

Ninth Circuit Upholds DFPI's Commercial Financing Disclosure Rules

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On September 30, 2018, California enacted SB 1235, codified at California Financial Codes sections 22800–22805. SB 1235 requires that an offer of commercial financing for $500,000 or less be accompanied by disclosures of: (1)...more

Hudson Cook, LLP

CFPB Bites of the Month - April 2025 - "I'll Remember April and the CFPB"

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In this month's article, we share some of our top "bites" covered during the April 2025 webinar....more

Blank Rome LLP

Navigating New Compliance Challenges for Financial Institutions and Payment Processors: The U.S. Treasury’s Enhanced Terrorist...

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In a significant move to combat illicit financial activities focused on cartels, the U.S. government has intensified its scrutiny of cross-border payments, particularly those linked to Mexico. This development follows the...more

Shipkevich PLLC

CFPB Memo Outlines New Supervision and Enforcement Priorities for 2025

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On April 16, 2025, Mark Paoletta, Chief Legal Officer of the Consumer Financial Protection Bureau (CFPB or the Bureau), issued an internal memorandum to CFPB staff outlining the agency’s supervision and enforcement priorities...more

Alston & Bird

2025 State Cybersecurity Legislation Focuses on Financial Services

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Eight years ago, on March 1, 2017, the New York Department of Financial Services enacted its landmark cybersecurity regulation covering financial services companies, 23 NYCRR Part 500, known as “Part 500.” Part 500 was the...more

A&O Shearman

UK PRA proposed fees for 2025/26

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The Prudential Regulation Authority (PRA) has published a consultation setting out proposals for its fees for 2025/26. The proposals would make amendments to the Fees Part of the PRA Rulebook (Appendix) and include: (i) the...more

Orrick, Herrington & Sutcliffe LLP

Treasury’s Bessent outlines vision for community banks

On April 9, the Secretary of the Treasury, Scott Bessent, delivered a speech outlining the Trump Administration’s financial policy goals of empowering community banks, moving away from prioritizing large financial...more

Orrick, Herrington & Sutcliffe LLP

Treasury issues final rule to eliminate several regulations

On April 15, the Treasury issued a direct final rule to eliminate several regulations or portions of regulations it deemed unnecessary in response to an Executive Order 14219 directing agencies to pursue deregulation. The...more

Orrick, Herrington & Sutcliffe LLP

CFPB memo outlines supervision and enforcement agendas under new administration

On April 16, the CFPB’s Chief Legal Officer, Mark Paoletta, issued a memo outlining the CFPB’s 2025 supervision and enforcement priorities, explaining that the CFPB intends to focus resources towards threats to service...more

Orrick, Herrington & Sutcliffe LLP

OCC announces changes to its organizational structure

On April 16, the OCC announced several changes to its organizational structure to align its supervisory approach to the agency’s priorities. The OCC announced the combination of the Midsize and Community Bank Supervision and...more

Orrick, Herrington & Sutcliffe LLP

OCC provides an update on its security breach given institutional risk

On April 14, the OCC released a letter providing more details on the recent security breach involving its email systems. The breach — identified as a major incident under the Federal Information Security Modernization Act...more

Orrick, Herrington & Sutcliffe LLP

North Dakota expands its financial data security framework, includes alternative financing providers to obtain money broker...

On April 11, North Dakota enacted HB 1127 (the “Act”), amending the regulatory framework for financial institutions within the state by establishing a new chapter focused on data security programs. The Act amends various...more

Orrick, Herrington & Sutcliffe LLP

Arkansas adds crypto kiosk provisions to its money transmission act

On April 14, Arkansas enacted HB 1467 (the “Act”) to amend the Arkansas Uniform Money Services Act to enhance consumer protection and transparency in virtual currency transactions, particularly those through kiosks. The Act...more

Orrick, Herrington & Sutcliffe LLP

FDIC updates electronic communication procedures for supervisory correspondence

On April 15, the FDIC announced updated guidance on sending official correspondence related to supervisory matters. The FDIC’s guidance made permanent those temporary, previous measures for electronically sending and...more

Paul Hastings LLP

Daily Financial Regulation Update -- Monday, April 21, 2025

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April 18, 2025 - The Federal Reserve and the Office of the Comptroller of the Currency have conditionally approved the merger of Discover Bank, Greenwood, Delaware, into Capital One, National Association, McLean, Virginia....more

Orrick, Herrington & Sutcliffe LLP

Senators request investigation into FHFA board overhaul and workforce reductions

On April 15, ten U.S. Senators sent a letter addressed to Mr. Brian M. Tomney, Inspector General of the FHFA, requesting that the FHFA OIG review recent actions taken by FHFA leadership to overhaul the boards at Fannie Mae...more

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