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 April 10, the U.S. Treasury Department and Internal Revenue Service (IRS) issued proposed regulations (IR-2026-48) implementing the new 1% remittance transfer excise tax under the One, Big, Beautiful Bill. The excise tax applies beginning January 1, 2026, to remittances sent from the U.S. to foreign recipients when the sender uses cash, money orders, cashier’s checks, or similar physical instruments, with the sender primarily liable but remittance transfer providers required to collect the tax, make semimonthly deposits, and report it quarterly on Form 720 (and becoming liable themselves if they fail to collect). The proposed rules clarify the taxable base amount, define which physical instruments trigger the tax, and include illustrative examples, note prior limited penalty relief in Notice 2025-55 for underdeposits in the first three quarters of 2026, and invite public comments through Regulations.gov by June 12, 2026. For more information, click here.
On April 10, the Federal Deposit Insurance Corporation (FDIC) announced that it is rescinding, effective immediately, its prior supervisory guidance in FIL-32-2023 on multiple representment nonsufficient funds (NSF) fees — guidance that had itself replaced FIL-40-2022 — after concluding that FIL-32-2023 was overly broad and created uncertainty about when disclosures related to re-presentments might be considered “unfair” under Section 5 of the Federal Trade Commission (FTC) Act. The FDIC clarified that this change applies to all FDIC-supervised institutions and emphasized that banks must continue to ensure their consumer disclosures accurately describe their actual practices and comply with all applicable laws, regulations, and other current legal requirements. For more information, click here.
On April 10, the CFTC announced the formation of an Innovation Task Force (ITF) to help develop a clear regulatory framework for innovators working with crypto assets and blockchain technologies, artificial intelligence and autonomous systems, and prediction markets and event contracts. Led by Michael J. Passalacqua, the ITF is composed of CFTC staff from multiple divisions and offices, along with professionals who bring significant private sector experience in digital assets, financial regulation, and emerging technologies. Chairman Michael S. Selig emphasized that the ITF is intended to provide “clear rules of the road” for American innovators. Initial members include senior advisors Hank Balaban, Sam Canavos, Mark Fajfar, Eugene Gonzalez IV, and Dina Moussa, each of whom has substantial legal, regulatory, or advisory experience in digital assets, fintech, market regulation, or related practice areas. For more information, click here.
On April 10, the Board of Governors of the Federal Reserve System proposed amendments to subpart C of Regulation J to allow FedNow Service participants to use intermediaries other than Federal Reserve Banks — such as correspondent banks — for the international leg of cross-border transactions while using FedNow for the U.S. domestic portion, thereby creating a second real-time gross settlement rail for private-sector cross-border payment solutions alongside Fedwire. The proposal would align FedNow’s rules with Fedwire by permitting Reserve Banks to rely on routing numbers identifying intermediary banks, allow FedNow payment orders to designate non-Reserve Bank intermediaries (without changing which entities can connect to FedNow), and clarify that the existing immediate funds-availability requirement continues to apply only when a U.S. beneficiary’s bank itself receives the payment order over FedNow. The Board preliminarily concludes the changes raise no material new money-laundering, sanctions-evasion, or payment-system integrity risks, impose no new reporting or recordkeeping burden under the Paperwork Reduction Act, and will not have a significant economic impact on a substantial number of small entities, and it requests public comment on all aspects of the proposal by June 9, 2026. For more information, click here.
On April 9, the Federal Communications Commission (FCC) released a further notice of proposed rulemaking in its unlawful robocalls and Telephone Consumer Protection Act dockets proposing to strengthen “Know-Your-Customer” (KYC) obligations for originating voice service providers by specifying the customer information they must collect, verify, retain, and periodically reverify before allowing new or renewing customers to place calls, including obtaining names, physical addresses, government-issued identification numbers, alternate phone numbers, and, for high‑volume customers, intended use of the service and relevant IP address information. The Commission seeks comment on risk‑based, enhanced KYC requirements (for example, for high‑volume, foreign, or otherwise higher‑risk customers), potential differences in standards for prepaid versus postpaid services, and how KYC obligations should respond to red flags such as unusual traffic patterns, with the aim of preventing illegal robocalls from ever entering the network and improving law enforcement’s ability to identify bad actors. The item also proposes that violations of the KYC rule be penalized on a per‑call basis to better align forfeitures with the volume and harm of illegal traffic, and it asks how enhanced KYC can help deter other criminal uses of communications networks, including fraud and more serious criminal activity, with comments due 30 days and reply comments 60 days after Federal Register publication. For more information, click here.
On April 9, the U.S. Treasury’s Office of Cybersecurity and Critical Infrastructure Protection launched a new initiative to provide free, timely, actionable cybersecurity threat information to eligible U.S. digital asset firms and industry organizations, extending to them the same high-quality cyber intelligence traditionally shared with banks in order to help identify, prevent, and respond to increasingly sophisticated attacks on their customers and networks. The launch advances a key recommendation of the President’s Working Group on Digital Asset Markets and operationalizes the GENIUS Act’s emphasis on responsible, cyber-resilient innovation as digital assets become more integrated into the broader U.S. financial system. For more information, click here.
On April 8, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) issued a joint proposed rule to implement the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act’s anti-money laundering (AML) and sanctions compliance requirements for payment stablecoin issuers, treating permitted payment stablecoin issuers (PPSIs) as financial institutions under the Bank Secrecy Act (BSA) and requiring them to maintain effective AML and sanctions compliance programs designed to counter illicit finance risks while supporting innovation and U.S. leadership in the payment stablecoin ecosystem. For more information, click here.
On April 8, the White House released an analysis of the GENIUS Act’s prohibition on stablecoin yield, finding that while the law requires stablecoin issuers to hold fully backed reserves in very safe assets and bars them from paying interest directly to holders (with some potential loopholes via affiliates that the proposed CLARITY Act might close), its impact on bank lending is minimal and comes at a net welfare cost. Using a simple model, the Council of Economic Advisers estimates that eliminating stablecoin yield would actually increase bank lending by only $2.1 billion (about 0.02%), with a net welfare loss of $800 million and a cost-benefit ratio of 6.6, with large banks doing about 76% of the extra lending and community banks about 24% (roughly $500 million, or a 0.026% lending increase for community banks). Even under stacked, highly unrealistic worst-case assumptions — including a stablecoin market six times larger relative to deposits, all reserves held as nonlendable cash instead of Treasuries, and a fundamental shift in Federal Reserve policy — the model yields just $531 billion in additional lending (a 4.4% increase overall), with community bank lending rising only $129 billion (6.7%), and the conditions needed to show a positive welfare effect are similarly implausible. The report concludes that prohibiting stablecoin yield would do very little to bolster bank lending while significantly sacrificing the consumer benefits of competitive returns on stablecoin holdings. For more information, click here.
On April 7, the Office of the Comptroller of the Currency (OCC) and the FDIC issued a final rule to remove “reputation risk” from their supervisory and examination frameworks and sharply limit their ability to influence banks’ customer relationships based on political or ideological grounds. This final rule is a central implementation step for President Trump’s debanking initiative under Executive Order 14331, “Guaranteeing Fair Banking for All Americans,” which aims to address concerns about financial institutions improperly restricting access to banking services based on customers’ political, religious, or ideological beliefs. The OCC, FDIC, and Federal Reserve Board (FRB) had previously committed to removing “reputation risk” from their supervisory programs, but the OCC and the FDIC are the first agencies to finalize a rule that does so. The FRB is on track to finalize its own rule, as it issued a proposed rule to codify similar regulatory constraints on February 23, 2026. For more information, click here.
On April 7, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) that would significantly revise BSA/AML and countering the financing of terrorism (CFT) program requirements across a broad range of financial institutions. The proposal is a central element of the U.S. Department of the Treasury’s effort to modernize the AML/CFT framework by moving away from purely technical, process-driven compliance toward demonstrable effectiveness in identifying, mitigating, and reporting money laundering, terrorist financing, and related illicit finance risks. If adopted, the rule would require covered institutions to recalibrate their AML/CFT programs to be genuinely risk-based, to integrate FinCEN’s AML/CFT priorities into their risk assessment processes, and to satisfy clear expectations regarding governance, independent testing, and the defined role of a U.S.-based AML/CFT officer. For banks, the proposal would also introduce a new supervision and enforcement framework that concentrates significant actions on material failures to implement an otherwise properly established program and strengthens FinCEN’s central role in AML/CFT oversight. Comments are due 60 days after publication in the Federal Register, and FinCEN proposes a 12‑month implementation period following issuance of a final rule. For more information, click here.
On April 7, the FDIC Board of Directors approved a notice of proposed rulemaking to implement key requirements of the GENIUS Act by establishing a prudential framework for FDIC‑supervised permitted payment stablecoin issuers, including standards for reserve assets, redemption practices, capital, and risk management. The proposal would also impose requirements on FDIC‑supervised issuers and insured depository institutions that provide custodial and safekeeping services for payment stablecoins, address when pass‑through insurance may apply to deposits held as reserves backing payment stablecoins, and clarify that tokenized deposits meeting the statutory definition of “deposit” are treated like any other deposit under the Federal Deposit Insurance Act. Comments will be accepted for 60 days after publication in the Federal Register. For more information, click here.
On April 6, U.S. Securities and Exchange Commission (SEC) Chair Paul Atkins said his proposed crypto “safe harbor” framework — featuring a startup exemption that would let crypto projects raise limited capital over four years while providing specified disclosures and investor protections — has advanced to White House review at the Office of Information and Regulatory Affairs, with a formal rule proposal expected “shortly.” He further emphasized that this initiative, alongside a companion “investment contract safe harbor” linked to the SEC’s recent token taxonomy guidance and a separate innovation exemption or regulatory sandbox for onchain assets, is unfolding amid broader but stalled congressional efforts to enact more permanent crypto legislation that regulators say they need “chiseled in stone” to ensure regulatory stability across administrations. For more information, click here.
State Activities:
On April 8, the Receivables Management Association International, ACA International, and Progressive Management Systems filed a class action lawsuit against the California Department of Financial Protection and Innovation (DFPI) challenging the fee structure under the California Debt Collection Licensing Act as an unlawful tax in violation of Proposition 26, arguing that DFPI set fees based on an assumption of 7,000 licensees but is currently regulating only about 1,243, that its gross‑receipts-based assessments are disproportionate to larger firms’ actual regulatory burdens or benefits, and that DFPI’s broad discretion over audit frequency, scope, and cost renders those charges unreasonably high and unpredictable. The suit follows DFPI’s first annual assessments issued on September 30, 2025, which, under a pro rata structure unique to California’s 2020 licensing law (making it the 35th state to license debt collectors), ranged from $250 to $1,421,404, with roughly 40% of licensees paying thousands more than in any other state. The associations characterize the litigation as part of their broader effort to defend the receivables industry’s role in the credit-based economy. For more information, click here.
On April 6, Maine Governor Janet Mills signed LD 2129, An Act to Strengthen Consumer Protections by Prohibiting Liens on Principal Residences and Wage Garnishments for Medical Debt, which bars medical debt collectors from placing liens on Mainers’ primary homes or garnishing their wages, building on prior legislation she signed that removed medical debt from consumer credit reports. Sponsored by Senator Donna Bailey of Saco, a cancer survivor, the law is intended to shield families facing medical crises from losing their homes or paychecks and is strongly supported by nonprofit groups who emphasize that nearly half of Maine households have incurred medical debt in the past two years and many struggle to afford basic necessities as a result. The measure is part of Mills’ broader effort since 2019 to expand and protect access to affordable health care in Maine, including Medicaid expansion, and will take effect 90 days after adjournment of the Second Regular Session of the 132nd Legislature. For more information, click here.
On April 3, Kentucky enacted SB 158, a comprehensive statute governing products that offer benefits in connection with personal property, with a particular focus on add‑on products sold with vehicle finance and lease transactions. SB 158 has three core objectives. First, it defines and regulates a set of vehicle-related financial products — primarily auto finance guaranteed asset protection (GAP) waivers, auto lease excess wear-and-use waivers, and vehicle value protection agreements — and imposes disclosure, cancellation, and financial-backstop requirements on issuers of those products. Second, it draws a bright line between those products and traditional insurance by expressly excluding them from the Kentucky Insurance Code and separately regulating “credit personal property insurance,” from which these products are carved out. Third, it amends Kentucky’s motor vehicle retail installment and consumer loan statutes to ensure that dealers, sales finance companies, and consumer lenders must follow the new framework when they offer these products. Most vehicle financial protection provisions apply to products that become effective on or after January 1, 2027. For more information, click here.
On April 2, Alabama enacted SB277, which, among other things, creates the Decentralized Unincorporated Nonprofit Association Law establishing decentralized unincorporated nonprofit associations as distinct legal entities and setting out comprehensive rules for their formation, governance, and dissolution. The act defines key concepts such as administrators, members, membership interests, governing principles, digital assets, distributed ledger technology, and smart contracts; permits these associations (with at least 100 members) to own property, engage in profit-making activities for nonprofit purposes, and operate and govern themselves through distributed ledger-based mechanisms and algorithmic consensus, while generally shielding members and administrators from personal liability for association obligations. It also addresses internal governance (including voting, membership changes, fiduciary standards, indemnification, and information rights), procedures for holding and transferring real property, litigation and service of process, venue, winding up and distribution of assets, and the possibility of merger or conversion under Alabama law. West Virginia is considering a similar bill, currently engrossed and pending before the Senate Judiciary Committee, that would likewise recognize decentralized unincorporated nonprofit associations as legal entities and enact a Decentralized Unincorporated Nonprofit Association Act. For more information, click here and here.
On April 1, the Connecticut banking commissioner issued a consent order against Zions Debt Holdings, LLC and its managing members resolving an investigation prompted by a consumer complaint and allegations that Zions operated as an unlicensed consumer collection agency in Connecticut, violated a 2024 consent order, used harassing and deceptive email communications with a Connecticut consumer, and failed to maintain adequate compliance policies and procedures. After Zions presented evidence of post-2024 internal policies prohibiting Connecticut contacts and disciplinary actions against violating employees, the commissioner found changed conditions, vacated a February 10, 2026 final order, and imposed reduced sanctions requiring respondents to cease and desist from unlicensed collection, abusive or misleading practices, and supervisory failures, to report any contact with Connecticut consumers for five years, to accept a five-year bar on Zions acting as a consumer collection agency in Connecticut, to pay a $50,000 civil penalty and $400 in back licensing fees, and to refrain from denying the allegations in the order. For more information, click here.