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 filings and applications and during Community Reinvestment Act (CRA) assessments. National banks and federal savings associations are now on notice that prior allegations of politicized
On July 29, 2025, Sens. Ruben Gallego (D-AZ) and Jim Justice (R-WV) introduced the Keep Call Centers in America Act of 2025. The act targets the offshoring of call center operations, imposes new disclosure rules for customer service interactions, and ties federal funding eligibility to domestic operations. Oversight of foreign call centers is not a
Late last year, we predicted that the Trump administration would bring federal action to target de-banking, and on August 7, 2025, President Trump signed a much-anticipated executive order to address the issue. Banks and credit unions should now expect to feel the impact early on in the form of horizontal reviews and inquiries from their
On June 20, 2025, the Supreme Court issued perhaps the most momentous decision in Telephone Consumer Protection Act history with McLaughlin Chiropractic Associates, Inc. v. McKesson Corp. This landmark ruling jettisons decades of established practice that bound district courts to follow the Federal Communications Commission (FCC) interpretations of the TCPA.
TCPA litigation has already been
In recent days, Federal Housing Finance Agency (FHFA) Director Bill Pulte has made it clear that he believes fraud is a rampant problem at FHFA. In a stream of related activities, Pulte has called on the public to report fraud via email and a new Hotline, terminated over 100 FHFA employees for alleged fraud, and
Last year, the FCC adopted new rules under the Telephone Consumer Protection Act (TCPA) designed to expand consumers’ rights to revoke consent to receive robocalls and text messages. As we noted in a prior post, these changes were set to take effect on April 11, 2025, and would require businesses to treat any valid
The Federal Communications Commission (FCC) has a new rule under the TCPA for revocation of consent for robocalls and text messages set to go into effect on April 11, 2025. This rule is designed to give consumers greater control over their ability to withdraw consent for marketing communications. Businesses that use text messaging and
The start of the second Trump administration is fast approaching, and it raises prospects of a renewed push for federal-level fair access to banking requirements. The first Trump administration came close to enacting such a regulation in its last weeks, but the rule was halted by the Biden administration. The financial services industry should not
On October 10, 2024, Attorney General Merrick Garland announced that TD Bank agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice’s (DOJ) investigation into money laundering and Bank Secrecy Act (BSA) violations. When combined with agreements with the Federal Reserve, Office of the Comptroller of the Currency (OCC), and
On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) rulemaking board proposed new recordkeeping rules intended to bolster the FDIC’s ability to make deposit insurance determinations for accounts that are the product of a partnership between an FDIC-insured depository institution (IDI) and a financial technology company (fintech). However, despite the proposed rule’s focus on