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, the Financial Crimes Enforcement Network (FinCEN) and the federal banking regulators issued joint guidance in the form of Suspicious Activity Report (SAR) FAQs clarifying several
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 compare and contrast common home equity products, including home equity lines of credit (HELOC), closed-end home equity loans (HEL), reverse mortgages, and home equity agreements
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 significantly interferes with the exercise of a national bank’s powers and is, therefore, preempted by the National Bank Act. In doing so, the Supreme Court
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 for Innovation in Accessing Home Equity.” The title alone underscores the RFI’s importance for all participants in HUD’s Home Equity Conversion Mortgage (HECM) program
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 loan borrowers impacted by the various wildfires that occurred earlier in 2025, is in many ways reminiscent of the CARES Act forbearance framework from 2020.
Last month, in the unpublished opinion Olson v. Unison Agreement Corporation, the United States Court of Appeals for the Ninth Circuit found that a home equity investment (HEI) agreement met the definition of a reverse mortgage under Washington law and was not, as the company intended, a real estate option contract (2025 WL 2254522
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 binding itself to a clearer standard requiring a high likelihood of significant harm directly tied to financial products and services, the Bureau is signaling a
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
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