There has been much speculation that States will fill the void created by the Trump Administration’s drastic scaling back of the Consumer Financial Protection Bureau. Congress authorized both state attorneys general and state regulators (like New York’s Department of Financial
Latest from Consumer FinSights
Banks May Provide Cryptocurrency Transaction and Custody Services, but OCC Has Yet to Provide Clear Compliance Requirements
On May 7, 2025, the Office of the Comptroller of the Currency (“OCC”) issued a follow up to its July 2020 Interpretative Letter 1170, which allowed national banks to provide cryptocurrency custody services to their customers.[1] The May 7
Another Fintech Company Acquires a National Bank Charter through Merger
On March 17, 2025, the Office of the Comptroller of the Currency (OCC) announced that it conditionally approved a fintech business model for CenTrust Bank, N.A.’s (“CenTrust”), an Illinois based community bank chartered by the OCC.[1] CenTrust was acquired
California Enacts New Bill to Strengthen Customer Protection on Automatic Renewals
On September 24, 2024, California enacted Assembly Bill 2863 (the “Bill”) to take effect on July 1, 2025.[1] The Bill updates California’s regulations governing automatic renewals and continuous services. An automatic renewal or continuous service (“auto renewal contract”) is
CFPB Establishes New Obligations for Covered Nondepository Institutions Subject to Judicial or Administrative Enforcement Orders
On June 3, 2024, the Consumer Financial Protection Bureau imposed a new set of regulatory obligations on nondepository consumer-financial companies that are subject to court or administrative orders enforcing federal or state consumer-protection laws. The Bureau’s new rule creates a
CFPB Updates Process to Designate Nonbanks for Supervision
Yesterday, the Consumer Financial Protection Bureau updated its process for designating a nonbank for supervision. Initially issued in 2013, the revised rule specifically establishes the CFPB’s procedures in determining whether a nonbank “poses risk to consumers” and is thus subject
The FTC and CFPB Announce New Rules to Tackle Junk Fees
On October 11, 2023, President Biden, Federal Trade Commission (FTC) Chair Lina Khan, and Consumer Financial Protection Bureau (CFPB) Director Rohit Chopra announced the latest developments in the government’s efforts to tackle junk fees. Junk fees are hidden, surprise fees
Real-Estate Agents Who Participate in Joint Ventures Should Be Wary of the CFPB’s Recent Policy Statement on Abusive Conduct
Much has been written about the Consumer Financial Protection Bureau’s recent “Policy Statement on Abusive Acts or Practices,”[1] in which the Bureau analyzed the prohibition on abusive conduct in the Consumer Financial Protection Act of 2010 (CFPA).
Silvergate, Silicon Valley Bank, Bank Receiverships in General, and Payroll Regulatory Challenges
In the wake of Silvergate’s collapse, Silicon Valley Bank entering receivership and another bank following in SVB’s footsteps, startups and other companies directly affected by these events are struggling to manage their payroll and other obligations while credit facilities are
California Leads the Way on Commercial Lending Disclosures
In December 2022, California’s new commercial lending disclosure law and complementary regulations went into effect, leading the way for other states to follow.
The new California law imposes disclosure requirements in commercial lending transactions. While this is not new for