On August 13, 2026, U.S. District Judge Eric Komitee of the Eastern District of New York issued a decision in Spetner v. Palestine Investment Bank that should command the attention of every financial institution operating in the United States. The court allowed claims to proceed under the Anti-Terrorism Act (ATA) against Palestine Investment Bank (PIB)
On July 23, 2026, the Consumer Financial Protection Bureau (CFPB) updated its Equal Credit Opportunity Act (ECOA) Baseline Review Procedures. Notably, the updates were issued just two days after the final amendments to Regulation B, the regulation implementing ECOA, became effective. While the overall examination structure largely remains unchanged, the updates signal a shift
On July 20, 2026, the Federal Housing Administration (FHA) published a draft mortgagee letter that would significantly revamp portions of the loss mitigation process for FHA-insured mortgage loans. If enacted, the draft mortgagee letter would create a new method of structuring a partial claim called a Partial Claim Reinstatement Advance Payment (RAP). RAP would allow
On July 21, 2026, Financial Crimes Enforcement Network (FinCEN) Director Andrea Gacki appeared before the House Financial Services Subcommittee on National Security, Illicit Finance, and International Financial Institutions to deliver written testimony outlining the agency’s current priorities. The hearing provided a comprehensive window into FinCEN’s evolving posture on fraud prevention, Bank Secrecy Act (BSA) modernization
On July 14, 2026, a split 9th U.S. Circuit Court of Appeals panel affirmed a preliminary injunction barring enforcement of the Financial Crime Enforcement Network’s (FinCEN) border geographic targeting order (GTO), the rule requiring money service businesses (MSBs) along the U.S.-Mexico border to file currency transaction reports on cash transactions as low as $200. Writing
On July 6, 2026, the Consumer Financial Protection Bureau (CFPB) released its latest regulatory agenda, providing a roadmap of the regulatory activity that is to come and shedding light on the current administration’s priorities. Mortgage-related items dominate the agenda, driven in large part by Executive Order 14393, titled “Promoting Access to Mortgage Credit
As we have addressed on this blog, home equity investment (HEI) products, such as shared appreciation mortgages and home equity agreements, have come under recent scrutiny from regulators and industry groups. The crux of the debate is whether these products should fall under existing regulatory regimes for mortgage loans or require entirely new
On May 28, 2026, Secretary of State Marco Rubio announced that the U.S. Department of State designated Comando Vermelho (CV) and Primeiro Comando da Capital (PCC), Brazil’s two largest and most violent criminal organizations, as Specially Designated Global Terrorists (SDGTs) under Executive Order 13224 and as Foreign Terrorist Organizations (FTOs) under Section 219 of the
On May 21, 2026, the Office of the Comptroller of the Currency (OCC) made public an April 2026 consent order (AA-ENF-2025-21) against a federal savings association based in the Northeast for deficiencies in its Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance program. The order is the latest in a growing line of enforcement actions demonstrating that
On May 11, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an alert designed to help financial institutions identify and disrupt funding streams and procurement networks supporting Iran’s Islamic Revolutionary Guard Corps (IRGC). The alert arrives at a moment of intensified U.S. economic pressure on the Iranian regime — part