On April 16, 2025, the CFPB’s Chief Legal Officer, Mark R. Paoletta, issued a memorandum to CFPB staff that sets out the agency’s 2025 supervision and enforcement priorities.
Continue Reading CFPB Memo Details Less Oversight on Fintechs, Shift to State-Led Enforcement
On March 27, 2025, the Federal Trade Commission (FTC) filed a lawsuit and proposed settlement order resolving claims against Cleo AI, a fintech that operates a personal finance mobile banking application through which it offers consumers instant or same-day cash advances. The FTC alleges that Cleo deceived consumers about how much money they could get and how fast that money could be available, and that Cleo made it difficult for consumers to cancel its subscription service.
Continue Reading FTC Alleges Fintech Cleo AI Deceived Consumers
Since taking office, President Trump reduced the Consumer Financial Protection Bureau’s influence by appointing Russell Vought as acting director, who paused rulemaking, enforcement, and other CFPB activities. This shift impacts bank-fintech partnerships, requiring industry adjustments.
Continue Reading The Current And Future State Of Bank-Fintech Partnerships
On Nov. 21, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule (Rule), pursuant to 12 U.S.C. § 5514(a)(1)(B), to establish supervisory authority over nonbank entities identified as larger participants in the general-use digital consumer payment applications market. While the CFPB already has enforcement power over digital funds transfer and payment wallet app
On Nov. 18, 2024, the Federal Deposit Insurance Corporation (FDIC) announced a 45-day extension to the public comment period for its proposed rule making (Proposed Rule) that would establish new recordkeeping requirements and related compliance obligations for insured depository institutions that offer certain “custodial deposit accounts with transactional features.”
As we detailed in a prior
On Oct. 2, 2024, the Federal Deposit Insurance Corporation (FDIC) published a notice of proposed rulemaking (Proposed Rule) designed to strengthen recordkeeping requirements for custodial deposit accounts with transactional features, like those often used in banking-as-a-service (BaaS) models and other bank-fintech partnerships. The Proposed Rule is intended to ensure the FDIC’s ability to promptly make
On Nov. 7, 2023, the Consumer Financial Protection Bureau (CFPB) released a proposed rule that would, if finalized in its present form, establish the CFPB’s supervisory authority over certain “larger participant” nonbank companies that provide digital wallets and payment applications. The proposed rule, called the “Defining Larger Participants of a Market for General-Use Digital Consumer
On Oct. 25, 2023, the Fed proposed a rule to lower the interchange fee cap in Regulation II, which is largely applicable to debit card issuers with at least $10 billion in consolidated assets. The proposed rule would be the first time that the debit interchange cap has been adjusted since its implementation via the
Big Tech companies, fintechs, and traditional financial institutions are paying attention to the Consumer Financial Protection Bureau’s (CFPB) September 2023 issue spotlight, which focuses on tap-to-pay or contactless payment technology. The CFPB’s report highlights the role of Big Tech companies in the mobile payment space.
Crypto-asset businesses, particularly those offering crypto lending, non-fungible tokens, or digital wallet/payments products — which are already facing intense scrutiny from the SEC, CFTC, U.S. Department of Justice and U.S. Department of the Treasury — should not neglect the need to prepare for CFPB and FTC scrutiny. This article explores this trend by the CFPB