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 Vought in the acting director position so he can shutter or even more substantially shrink the CFPB and the laws it enforces. But the CFPB’s
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 August 26, 2025, the Consumer Financial Protection Bureau (CFPB or the Bureau) published a proposed rule that would narrow its supervisory authority over nonbanks. Under the proposed rule, the CFPB plans to exercise oversight over nonbanks only in cases where there is a “high likelihood of significant harm to consumers.”
If finalized, the rule
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
Starting July 1, 2025, Idaho will subject financial institutions with total assets over a certain threshold to new restrictions under the Transparency in Financial Services Act. The law follows a growing trend among states seeking to ensure fair access to banking and prevent financial denials based on political, religious, or ideological factors — often known
On Thursday, November 21, 2024, the Consumer Financial Protection Bureau (CFPB) published a final rule that will soon provide it with supervisory authority over large companies in the general-use digital consumer payment applications market. This rule will become effective 30 days after it is published in the Federal Register and will subject large participants in
On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) finalized its long-anticipated rule implementing Section 1033 of the Dodd-Frank Act. The 594-page final rule arrives nearly one year after the CFPB’s proposed rule, which received over 11,000 comments from industry participants concerning its implementation. The rule requires institutions that issue credit cards and hold
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
On July 1, 2024, banks and other financial institutions doing business in Florida will be required to comply with new rules designed to ensure fair access to banking and prevent politically or ideologically motivated denial of services. While Florida-licensed and chartered banks have been subject to some of these rules since the enaction of the
Over the past two years, we’ve been covering the state legislatures and executive officials taking aim at environmental, social and governance (ESG) investing and ramping up the pressure on companies that incorporate ESG factors into business decisions. Financial services companies have been watching carefully to see what’s next in the state pushback to ESG. And