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To keep you informed of recent activities, below are several of the most significant federal events that have influenced the Consumer Financial Services industry over the past week.
Federal Activities:
On August 28, Federal Reserve Chairman Kevin Warsh delivered his first major public address since assuming the chairmanship, marking his 100th day in office at the Jackson Hole Economic Policy Symposium, covering four principal topics: the Fed’s approach to artificial intelligence and productivity, forward guidance, monetary policy principles, and his current assessment of the economy. On AI, Warsh described the technology as a potential new factor of production and announced the formation of internal Fed task forces to study AI’s implications for the economy and monetary policy, while cautioning that their findings would have no bearing on near-term policy decisions. On forward guidance, Warsh signaled a meaningful philosophical break from recent Fed practice, arguing that regular forward guidance has “overstayed its welcome” in normal times, risks creating a ”hall-of-mirrors” dynamic in which markets look to the Fed rather than forming independent economic judgments, and may have contributed to the delayed policy response to the 2021 inflation surge — pledging instead a quieter, more circumspect communications approach focused on getting policy right rather than managing market expectations. He outlined seven key monetary policy principles, including a firm 2% PCE inflation target, a rejection of the view that the dual mandate works at cross-purposes, a preference for conventional interest rate tools over unconventional policies except in genuine crises, and a notable emphasis on the importance of money even as financial innovations complicate the traditional monetary transmission mechanism. On the economy, Warsh described an overall picture of resilience and strength — business capital expenditures rising approximately 9% on a four-quarter basis driven largely by AI-related investment, S&P 500 profits up more than 20% over the past year, consumer spending up over 2%, private domestic final purchases growing at nearly 3%, and unemployment at 4.1% consistent with full employment, but identified inflation as the Fed’s “predominant focus,” noting that the 12-month PCE inflation rate stands at 3.7% and the six-month rate at 4.1%, both well above the 2% target. For more information, click here.
On August 28, the Federal Deposit Insurance Corporation (FDIC) released its Community Reinvestment Act (CRA) examination schedules for the fourth quarter of 2026 (October 1 through December 31, 2026) and the first quarter of 2027 (January 1 through March 31, 2027), fulfilling the regulatory requirement that each federal bank and thrift regulator publish its quarterly CRA examination schedule at least 30 days before the start of each quarter. The CRA, enacted in 1977, requires the FDIC to assess banks’ records of meeting the credit needs of their entire communities, including low- and moderate-income neighborhoods, consistent with safe and sound operations. Examination frequency is tied to an institution’s asset size and CRA rating, with institutions holding $250 million or less in assets and a Satisfactory rating subject to examination no more than once every 48 months, and those with an Outstanding rating no more than once every 60 months, absent reasonable cause. The published schedules are based on the best information currently available and are subject to change. For example, an unscheduled institution may be examined in connection with a deposit facility application, or resource constraints may delay previously scheduled examinations, with any rescheduled institutions to be noted on a subsequent list. The FDIC encourages public comment on institutions scheduled for CRA examination, with comments directed either to the institution itself or to the deputy regional director of the appropriate FDIC regional office, and all public comments received prior to completion of an examination will be considered. For more information, click here.
On August 28, the FDIC published two additional notable updates. First, it released an updated version of its Consumer Compliance Examination Manual, which serves as a key reference for examiners conducting consumer compliance reviews of FDIC-supervised institutions. Second, the FDIC extended the public comment period on its proposed rule titled “Disclosure of Information,” originally published in the Federal Register on June 30, 2026, moving the comment deadline from August 31, 2026, to October 5, 2026, in response to requests from interested parties seeking additional time to analyze the proposal and prepare comments. The underlying proposed rule would update, clarify, and supplement the FDIC’s regulations governing disclosure of confidential information, including by enhancing the ability of insured depository institutions to share confidential supervisory information with affiliates and certain other entities for appropriate business purposes without prior FDIC authorization, significantly simplifying the requirements applicable to the FDIC’s discretionary disclosure of confidential information, updating the agency’s Freedom of Information Act disclosure rules, and clarifying how and when FDIC information may be disclosed in connection with legal proceedings or as a result of service of process on the FDIC and its directors, officers, and employees. For more information, click here and here.
On August 27, the Office of the Comptroller of the Currency (OCC) announced a series of significant actions designed to improve transparency, consistency, and clarity in bank supervision and enforcement. The actions — which include a joint final rule with the Federal Deposit Insurance Corporation (FDIC), two revised policies and procedures manuals (PPMs), and a proposed rulemaking — reflect the agencies’ stated commitment to refocusing supervisory attention on material financial risks over process, documentation, and other nonfinancial concerns. At the center of these actions is a final rule issued jointly by the OCC and FDIC that, for the first time, formally defines the term “unsafe or unsound practices” — a standard that has long been central to bank supervision but has never carried a statutory or regulatory definition. Under the new rule, unsafe or unsound practices are those that are contrary to generally accepted standards of prudent operation and that, if continued, could materially harm the institution or present a material risk of loss to the Deposit Insurance Fund. This definition marks a meaningful departure from the Federal Reserve’s current standard, which remains rooted in the concept of “abnormal probability of abnormal harm” as reflected in the Fed’s operating manual updated as recently as May 2026. Whether the Federal Reserve will move to align its definition with the OCC and FDIC’s materially focused standard, or maintain its own distinct approach, remains an open question. The rule also establishes uniform standards for when and how the agencies may issue Matters Requiring Attention (MRAs) as part of the examination process, and clarifies how supervisory observations and violations of laws and regulations will be communicated to institutions. For more information, click here.
On August 27, the FDIC’s Division of Risk Management Supervision presented to the FDIC Board of Directors an Interim Final Rule (IFR) implementing § 902 of the 21st Century ROAD to Housing Act, which became law on July 11, 2026, and amends the reciprocal deposits exception to the brokered deposit restrictions under § 29 of the Federal Deposit Insurance Act. The IFR makes two principal regulatory changes corresponding to the two statutory amendments enacted by the Housing Act. First, it expands the definition of “agent institution,” the category of institutions eligible to treat an amount of reciprocal deposits as non-brokered, by broadening the first prong of that definition to include well-capitalized institutions with a CAMELS composite rating of 3, in addition to the previously qualifying ratings of 1 and 2, thereby allowing a broader range of institutions to participate in reciprocal deposit networks without triggering brokered deposit treatment. Second, it replaces the prior general cap, which had been the lesser of $5 billion or 20% of total liabilities, with a new tiered calculation methodology: 50% of total liabilities up to $1 billion, plus 40% of total liabilities between $1 billion and $10 billion, plus 30% of total liabilities between $10 billion and approximately $96.3 billion, resulting in a maximum general cap of $30 billion for the largest qualifying institutions. Beyond these two core changes, the IFR also provides clarifying guidance on how agent institutions “receive” reciprocal deposits for purposes of the special cap applicable to downgraded institutions, and how an institution that loses agent institution status may requalify. The FDIC additionally announced plans to work through the Federal Financial Institutions Examination Council (FFIEC) to issue supplemental and ultimately final Call Report instructions to assist banks with reporting consistent with the new statutory framework. The Board was asked to approve the IFR and authorize its publication in the Federal Register with a 30-day comment period. For more information, click here.
On August 27, the Office of Management and Budget (OMB) posted notice of a pending Executive Order 12866 regulatory review of a final rule submitted by the OCC titled “Regulations on Implementing the GENIUS Act for Entities Subject to OCC Jurisdiction,” indicating that the rule, which implements the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act for OCC-supervised institutions, has been designated as economically significant and is subject to a statutory legal deadline, reflecting the administration’s prioritization of a regulatory framework for stablecoins under the OCC’s jurisdiction. For more information, click here.
On August 26, the Consumer Financial Protection Bureau’s (CFPB) Office of Inspector General released Report FMIC-C-012, “Impacts of Certain CFPB Workforce and Contract Actions on Agency Operations,” prepared in response to multiple congressional requests received between February and April 2025. The report examines the high-level operational effects of a series of actions taken by CFPB acting directors between February and April 2025, including agency-wide stop-work orders, the dismissal of 182 probationary and term employees, planned reductions in force (RIFs) affecting more than 1,400 employees, and the cancellation of nearly all of the agency’s 525 contracts. The OIG found that stop-work orders caused CFPB personnel to temporarily cease work on enforcement, supervision, and other core functions for approximately one month; that workforce reduction actions had limited operational impact because federal court orders halted or reversed their implementation; and that contract cancellations caused service disruptions to key operational systems, most notably the consumer complaint database, which stopped routing complaints to companies for approximately two weeks in February 2025 and contributed to a backlog of roughly 17,100 complaints requiring manual routing as of June 2026. The report does not assess whether the workforce or contract actions complied with applicable law, that question remains the subject of ongoing litigation, and notes as a scope limitation that current CFPB leadership declined to be interviewed for the review. The report’s release prompted an immediate political response. The next day, Senate Banking Committee Ranking Member Elizabeth Warren (D-MA) and Senator Andy Kim (D-NJ) issued a joint statement characterizing the report as revealing “the staggering extent to which the Trump administration’s assault on the CFPB has cost American families,” citing the cancellation of hundreds of contracts, a backlog of 16,000 consumer complaints, and the halting of 80 enforcement actions against companies they allege were cheating consumers, and claiming that Americans have paid at least $26 billion over the past year and a half as a result of the administration’s actions at the agency. For more information, click here and here.
On August 26, the Federal Trade Commission (FTC) announced updated fees for telemarketers to access phone numbers listed on the National Do Not Call (DNC) Registry for Fiscal Year 2027, which begins October 1, 2026. All telemarketers calling consumers in the U.S. are required to download and cross-reference numbers listed on the National DNC Registry before placing calls, to ensure they do not contact consumers who have registered their phone numbers. Telemarketers must renew their registry subscriptions annually. The first five area codes are available at no charge, and certain exempt organizations, such as qualifying charities and political callers, may obtain the full list for free. For more information, click here.
On August 25, seven federal agencies — the FDIC, OCC, CFPB, National Credit Union Administration (NCUA), Department of Housing and Urban Development, U.S. Department of Justice, and Federal Housing Finance Agency — jointly rescinded the February 2022 “Interagency Statement on Special Purpose Credit Programs Under the Equal Credit Opportunity Act and Regulation B,” effective immediately upon Federal Register publication. The agencies’ stated reason for the rescission was to clarify that creditors may not discriminate against borrowers based on prohibited characteristics, and that creditors should not rely on the Interagency Statement or related guidance going forward concerning special purpose credit programs (SPCPs). Curiously, the Federal Reserve Board, which joined in issuing the original Interagency Statement, was not a party to the notice of rescission, instead electing to separately withdraw its own version rather than join the other agencies in the joint rescission. The rescission follows a series of executive orders issued by the Trump administration directing agencies to review sub-regulatory guidance that may have sanctioned or encouraged discriminatory programs. For more information, click here.
On August 24, President Trump designated John Crews as the 14th chairman of the NCUA, following the Senate’s confirmation of Crews as a member of the NCUA Board of Directors on August 7, 2026 — a nomination the president had made on May 11, 2026. Crews was sworn in the same day, succeeding outgoing Chairman Kyle Hauptman, who served nearly six years in the role. In his remarks, Crews emphasized his commitment to building on the agency’s recent regulatory reform progress, identifying as his key priorities the safety, soundness, and resilience of the credit union system, fostering responsible innovation, promoting regulatory efficiency, maintaining a strong National Credit Union Share Insurance Fund, and expanding access to affordable financial services. Immediately prior to his NCUA appointment, Crews served as deputy assistant secretary for Financial Institutions Policy at the U.S. Department of the Treasury, focusing on regulation, financial infrastructure, and safety and soundness matters; he previously served as policy advisor to House Majority Leader Steve Scalise, policy director for the Senate Banking Committee, and as special assistant to the president for Economic Policy at the National Economic Council during the first Trump administration. Crews holds a bachelor’s degree in politics from Princeton University, and his NCUA term will expire on August 2, 2031. For more information, click here.
On August 24, the U.S. Department of the Treasury announced the launch of the Quantum-Readiness Task Force, a public-private initiative established pursuant to Trump’s Executive Order 14412, which directed the strengthening of cryptographic protections for America’s sensitive data, critical infrastructure, and digital economy. The Task Force is designed to accelerate the U.S. financial sector’s transition to quantum-safe technology in an orderly and operationally resilient manner, building on the G7 Cyber Expert Group’s roadmap for the transition to post-quantum cryptography, and will operate through three workstreams: Sector Alignment and Post-Quantum Cryptography (PQC) Transition; Third-Party and Vendor Readiness; and Digital Assets and Emerging Technology Risk. The initiative reflects growing concern that future quantum computing systems could break many of the cryptographic tools currently protecting financial data, payment systems, digital identities, and market infrastructure — a long-term cybersecurity threat that Treasury Secretary Scott Bessent described as requiring proactive action to keep the U.S. financial system “strong, secure, and competitive.” The Task Force will bring together government agencies, financial institutions, financial market infrastructures, technology providers, and other private-sector leaders to pursue practical, risk-based approaches to quantum readiness, including identifying critical dependencies, improving cryptographic agility, promoting interoperability, strengthening operational resilience, and addressing implementation challenges related to third-party vendors and digital assets. For more information, click here.
On August 18, Fannie Mae and Freddie Mac’s Uniform Appraisal Dataset (UAD) 3.6 and Forms Redesign team released updated Frequently Asked Questions as the industry approaches the November 2, 2026, mandatory implementation deadline, when UAD 3.6 will be required for all new appraisal reports submitted to the Uniform Collateral Data Portal (UCDP) — with reports submitted in the legacy UAD 2.6 format on or after that date receiving a fatal “Not Successful” submission result. The updated FAQs, several of which are new as of August 18, address a range of transition questions, including: how lenders should handle appraisals transferred from another lender after the mandate (the receiving lender may use the original DocFile ID and Successful Submission Summary Report for loan delivery purposes); whether loans with UAD 2.6 appraisals can still be sold to the GSEs after UAD 2.6’s May 3, 2027 retirement date (yes, as retirement applies only to UCDP submissions, not loan sales); how construction loans with “subject to completion” UAD 2.6 appraisals initiated before the mandate should be handled after completion (the Form 442/1004D or accepted alternative must be retained in the loan file for the life of the loan); and the meaning of “Site Owned in Common,” which refers to undivided interests in land commonly owned by an association and does not require reporting of Total Site Size. The updated FAQs also clarify that UAD 2.6 revisions to reports initially submitted before November 2, 2026, may continue to be submitted through the May 3, 2027, retirement date, and that lenders, appraisal management companies, and appraisers should begin transitioning immediately given that the mandate is based on the UCDP submission date rather than the loan application or effective date of the appraisal. For more information, click here.
State Activities:
On August 25, 39 state bankers associations announced the formation of the BankChain Alliance, an industry-owned, industry-designed, and industry-governed blockchain network intended to enable banks of all sizes to offer modern payment services including smart payment tools, tokenized deposits, stablecoins, and automated settlement, while maintaining the regulatory standards, security, and trust customers expect from their financial institutions. Interim Chair Kathy Kraninger, who also serves as President and CEO of the Florida Bankers Association, described the initiative as “an unprecedented collaboration representing thousands of banks” aimed at ensuring that institutions of all sizes can compete in an evolving digital financial landscape without ceding ground to non-bank competitors or large technology firms. The Alliance is currently conducting a rigorous technology partner selection process and is targeting a 2027 network launch; the BankChain Alliance network is designed to be interoperable with other networks and will be open to ownership participation by banks across the country. The participating associations collectively represent thousands of financial institutions serving millions of consumers, businesses, and communities nationwide across thirty-nine states, spanning Alabama, Arkansas, Connecticut, Delaware, Florida, Georgia, Hawaii, Idaho, Indiana, Iowa, Kansas, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Nebraska, Nevada, New Hampshire, New Jersey, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virginia, Washington, Wisconsin, and Wyoming. For more information, click here.
On August 10, the Washington State Department of Financial Institutions (DFI) issued a consent order against 3N Performance Partners, LLC, formerly known as OPX-America, LLC, resolving an investigation into the company’s unlicensed mortgage-related activities in Washington state. According to the order’s findings, between approximately December 21, 2023, and July 29, 2025, the company acted as a third-party loan processor and/or performed underwriting activities on at least 1,803 residential mortgage loans secured by real property in Washington without ever having obtained a consumer loan company license or mortgage broker license from the DFI — violations the Department concluded ran afoul of Washington’s Consumer Loan Act, related administrative rules, and federal law under 12 U.S.C. § 5103(b)(2). Under the terms of the Consent Order, 3N Performance Partners admitted the findings of fact and conclusions of law, agreed to cease and desist all violations of the Consumer Loan Act and applicable federal laws and regulations, and agreed to pay a total fine of $75,000 in three installments plus an investigation fee of $2,815.60 payable immediately. The order also clarifies that its entry does not preclude the company from pursuing its pending mortgage broker license application, though the company would need a separate consumer loan company license before resuming underwriting activities in Washington. For more information, click here.
On August 7, Connecticut Banking Commissioner Jorge L. Perez issued a consent order against Nelnet Servicing, LLC, doing business as Firstmark Services and Sloan Servicing, a Nebraska-based student loan servicer, resolving allegations that from January 1, 2022, through March 25, 2026 — the date Nelnet finally obtained its Connecticut small loan company license — Nelnet received payments on at least 1,114 small loans made to Connecticut borrowers without holding the required small loan company license, in violation of § 36a-556(a) of the Connecticut General Statutes. Without admitting or denying the allegations, Nelnet agreed to the following terms: a cease-and-desist obligation prohibiting it from receiving payments on small loans in Connecticut without maintaining the required licensure; implementation of due diligence policies and procedures to verify that the owners of small loans it services in Connecticut are either licensed as small loan companies or exempt from licensure, including obtaining written confirmation from creditors, conducting at least annual license verification against public databases such as NMLS Consumer Access, and retaining related records for at least two years after servicing ceases; payment of a $25,000 civil penalty; and payment of $800 in back licensing fees. The commissioner confirmed that upon issuance of the consent order the matter is resolved and no further enforcement action will be taken based on the alleged violations, provided Nelnet complies with the order’s terms, and the order will not affect Nelnet’s ability to obtain or renew licenses in Connecticut so long as all applicable legal requirements are met. For more information, click here.
International Activities:
On August 28, Pablo Hernández de Cos, general manager of the Bank for International Settlements (BIS), delivered a keynote address at the Jackson Hole Economic Symposium examining the monetary properties, macro-financial implications, and policy implications of stablecoins and tokenized deposits as competing paths for modernizing the monetary system. In a complementary address at the same symposium, European Central Bank (ECB) Executive Board Member Isabel Schnabel argued that central banks should go further still — not merely enabling access to central bank money on tokenized platforms, but bringing central bank reserves natively on-chain themselves, drawing on the ECB’s ongoing Pontes and Appia projects as a concrete path toward that goal. Drawing on the foundational properties that make money trustworthy — a common unit of account, singleness of money (meaning all monetary instruments are redeemable at par into central bank money with finality), elasticity of liquidity, interoperability, and financial integrity — de Cos argued that stablecoins in their current form fall materially short of these standards on multiple dimensions. Schnabel reinforced this point, arguing that while stablecoins could in principle be designed to satisfy a safety criterion, no stablecoin issuer possesses the independent capacity to expand liquidity elastically during periods of stress, which she identified as the defining and irreplaceable characteristic of central bank money. By contrast, both speakers argued that tokenized deposits — bank liabilities recorded on programmable platforms with interbank settlement through central bank accounts — preserve the two-tier monetary architecture, maintain singleness through settlement in central bank money, and present a more tractable path to harnessing the efficiency gains of tokenization, including programmability, atomic settlement, and around-the-clock operability, while noting that genuinely interoperable, multi-bank tokenized deposit ecosystems do not yet exist at scale. For more information, click here and here.