On Oct. 22, 2024, the CFPB issued a final rule that will require covered financial institutions to provide consumers and authorized third parties with access and portability options for their financial data. The CFPB’s final rule, called the “Personal Financial Data Rights Rule,” implements Section 1033 of Title X of the Dodd-Frank Act, a to-date…

The Securities and Exchange Commission’s Division of Examinations (Division) announced its 2025 examination priorities (Exam Priorities) Oct. 21, 2024. These priorities address areas of concern based on recent examinations, and often forecast referrals to the Division if material rule violations or deficiencies are uncovered. 

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The Corporate Transparency Act (CTA) has been in effect since Jan. 1, 2024, requiring non-exempt U.S. entities and non-exempt foreign entities that are registered to do business in the United States (collectively, Reporting Companies) to submit beneficial ownership information (BOI) reports to a confidential database maintained by the U.S. Department of the Treasury’s Financial Crimes…

On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued a Proposed Interpretive Rule and Request for Comment (Proposed Rule) addressing credit products in the paycheck advance marketplace, such as those marketed as “earned wage access” or “earned wage advance” products (EWA).

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On June 28, 2024, FinCEN issued a Proposed Rule to amend BSA regulations that prescribe the minimum requirements for AML/CFT programs for “financial institutions.” Financial institutions subject to AML/CFT program rules include banks, casinos and card clubs (casinos), money services businesses (MSBs), brokers or dealers in securities (broker-dealers), mutual funds, insurance companies, futures commission merchants…

On April 4, 2024, the CFPB issued a report titled “Banking in Video Games and Virtual Worlds” that examines the financial and privacy risks to consumers in online video gaming marketplaces.

The CFPB’s report explains that gaming platforms facilitate the storage and exchange of valuable assets while collecting large amounts of data from their users.

The Consumer Financial Protection Bureau (CFPB) and a coalition of trade-group plaintiffs filed dueling briefs last week over recusal standards in the Fifth Circuit lawsuit challenging the CFPB’s $8 credit card late fee final rule. On April 8, 2024, the court requested supplemental briefing on whether a judge’s ownership interest in a non-party large…

After years of rulemaking efforts, FinCEN issued a Notice of Proposed Rulemaking (Proposed Rule) Feb. 15, 2024, that would subject certain investment advisers to AML/CFT compliance requirements under the BSA. The Proposed Rule’s comment period runs through April 15, 2024. Covered investment advisers would be required to comply within 12 months from the final…

On March 5, 2024, the Consumer Financial Protection Bureau (CFPB) finalized a rule intended to limit late payment fees on credit cards issued by the largest credit card issuers. The final rule amends Regulation Z, reducing safe harbor late fee amounts for large card issuers from $30 to $8 and eliminating automatic annual inflation adjustments.