In an October 6 speech, the Federal Reserve’s Vice Chair for Supervision, Michelle Bowman, described a restructuring of the agency’s supervision function. The supervision function is currently organized according to the twelve Reserve Bank districts, which do not always follow state lines. The restructuring features a five-region system following state…
On October 14, 2026, the Consumer Financial Protection Bureau (“CFPB”) announced a new initiative to investigate potentially unlawful debanking practices by large financial institutions, signaling heightened regulatory scrutiny of account restrictions and terminations based on customers’ political or religious beliefs or lawful business activities. The CFPB’s announcement follows a report…
The Office of the Comptroller of the Currency (OCC), on October 14, 2026, released a report entitled Guaranteeing Fair Banking for All Americans. In September 2025, the OCC undertook a review of the activities of the then nine largest U.S. national banks based on asset size to determine whether those…
On October 21, 2026, the Office of the Comptroller of the Currency (OCC) announced a final rule implementing the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. The GENIUS Act, enacted on July 18, 2025, establishes a regulatory framework for payment stablecoin activities, defining a “payment stablecoin” as…
On October 1, the Consumer Financial Protection Bureau (CFPB) complied with statutory reporting requirements by releasing the Fair Lending Report of the Consumer Financial Protection Bureau for 2025, the CFPB’s summary of its fair lending work during 2025. The report boasts of a sweeping reorientation of the CFPB’s priorities from…
On September 25, 2026, the U.S. District Court for the District of Oregon granted partial summary judgment to a coalition of twenty-two states and the District of Columbia in State of New York v. Vought, No. 6:25-cv-02384-AA (D. Or.), holding that CFPB’s Acting Director Vought unlawfully refused to request funding…
On October 2, 2026, an association of community banks brought suit against the Office of the Comptroller of the Currency (the “OCC”), as well as Comptroller Jonathan V. Gould, in the United States District Court for the District of Columbia. The suit challenges a final rule issued by the OCC…
On September 16, 2026, the House Financial Services Committee completed its consideration of H.R. 10184, the Consumer Financial Protection Accountability and Reform Act of 2026, and ordered the amended bill to be reported favorably to the House of Representatives by a 28-21 vote. The proposed bill would substantially alter the…
The most consequential cyberattacks hitting the financial sector this summer did not start with malware or a zero-day exploit. They started with a phone call. According to research published in early August by Google’s Threat Intelligence Group, dozens of prominent U.S. financial institutions—including some of the country’s largest private equity…
On August 27, 2026, the Colorado Attorney General, together with the state’s Consumer Credit Code Administrator, filed a lawsuit in Colorado state court against a California-based financial technology company offering earned wage access products, alleging that the company has been operating an unlicensed, high-cost lending program in violation of the…
In August 2026, the California Department of Financial Protection and Innovation (DFPI) announced that it had entered into a consent order with Academy Mortgage Corporation resolving findings arising from a March 2023 ransomware attack, which signaled that a mortgage company’s ability to document cybersecurity governance may matter as much as…
In August, the Federal Deposit Insurance Corporation (FDIC) approved the deposit insurance application of Augustus National Bank, N.A., a newly chartered national bank that focuses on deposit and lending products for digital asset companies, technology companies, and artificial intelligence companies, as well as offering virtual currency, payment, and treasury services….
The United States House Committee on Financial Services has advanced H.R. 9330, the Earned Wage Access Consumer Protection Act, a bill that would establish a comprehensive federal regime for the regulation of earned wage access (EWA) services and establish nationwide rules and consumer protections, including those reinforcing the non-credit nature…
On July 1, 2026, Florida Attorney General James Uthmeier announced he issued a Civil Investigative Demand (CID) to a leading credit score issuer, commanding the production of documents and responses to questions to determine whether the company violated the Florida Antitrust Act. The CID focuses on allegations that the California-based company has maintained…
The Consumer Financial Protection Bureau (Bureau) recently issued a press release summarizing significant changes it has made to its consumer complaint portal. The Bureau’s explanation is blunt: the system has been abused, and that abuse impedes its ability to respond to legitimate complaints. For financial institutions—and particularly for the nationwide…
On June 17, 2026, the Consumer Financial Protection Bureau (CFPB) rescinded its December 2020 advisory opinion regarding Special Purpose Credit Programs (SPCPs) under the Equal Credit Opportunity Act (ECOA) and Regulation B. The Bureau stated that the advisory opinion no longer reflects current law and guidance following amendments to Regulation…
Continuing the current federal shift away from reputation risk in the bank supervisory space, the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC) and the Board of Governors of the Federal Reserve System jointly announced on June 2, 2026 that they had removed all…
In May 2026, the Office of the Comptroller of the Currency (OCC) released its Semiannual Risk Perspective report, warning that artificial intelligence (AI) is “significantly transforming” the cybersecurity threat landscape for banks. Specifically, the OCC found that AI can be used to facilitate fraud, while also lowering the barrier to…
In April 2026, the Office of the Comptroller of the Currency issued two coordinated interim actions addressing national banks’ authority to impose certain fees. The OCC adopted an interim final rule and final order clarifying that national banks have long possessed the power under federal law to assess non‑interest charges…
On April 17, 2026, the Consumer Financial Protection Bureau (CFPB) submitted a final rule to the Office of Information and Regulatory Affairs (OIRA) that would complete its overhaul of small-business lender data collection requirements originally issued during the Biden administration. The submission signals that the CFPB’s long-anticipated “reconsideration” of its…