Russ Vought’s CFPB has been busier over the past two weeks, but not because of increased enforcement or supervision efforts. Instead, recent actions indicate that the administration intends to keep…
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Florida Becomes Battleground for Text Messaging TCPA Arguments
In the wild new world of TCPA litigation following the end of binding deference to the Federal Communications Commission (FCC), one of the more salient questions is whether the Do-Not-Call…
Less Noise, More Signal: What FinCEN’s New SAR Guidance and the STREAMLINE Act Could Mean for BSA Reporting
Two recent developments signal that momentum is building in Washington to recalibrate Bank Secrecy Act (BSA) reporting to produce higher‑value intelligence with less compliance friction. First, on October 9, 2025…
Home equity products enable homeowners to unlock the value of their homes through a variety of financing contracts. Each product has distinct features, benefits, and risks. In this post, we…
In its 2024 decision Cantero v. Bank v. America, N.A., the Supreme Court established the approach courts must follow in determining whether a state consumer financial law prevents or…
The U.S. Department of Housing and Urban Development (HUD) published a request for information (RFI) on October 2, 2025 titled “Future of the HECM and HMBS Programs and Opportunities…
California Enacts Mortgage Forbearance Act, Effective Immediately; Will Pose Compliance Challenges for Servicers
On September 22, 2025, California Gov. Gavin Newsom signed the Mortgage Forbearance Act into law, with an immediate effective date. The law, designed to provide emergency relief to California mortgage…
Home Equity Investment and Shared Appreciation Agreements as Reverse Mortgages in Washington – Olson v. Unison Agreement Corporation
Last month, in the unpublished opinion Olson v. Unison Agreement Corporation, the United States Court of Appeals for the Ninth Circuit found that a home equity investment (HEI) agreement…
The Consumer Financial Protection Bureau’s (CFPB) latest proposed rule to define risks to consumers may appear technical, but its implications reach far beyond the narrow mechanics of supervisory designation. By…
OCC Announces That Debanking Practices Will Be Scrutinized During Bank Licensing and Community Reinvestment Reviews
On September 8, 2025, the Office of the Comptroller of the Currency (OCC) released Bulletin 2025-22, announcing that the OCC will assess an entity’s debanking practices when considering licensing…






