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 24, the U.S. Department of Justice (DOJ) ended its criminal investigation into Federal Reserve Chair Jerome Powell’s handling of a costly headquarters renovation, a move that removes a key obstacle to Senate confirmation of President Trump’s nominee, former Fed official Kevin Warsh, as the next chair. The probe, led by U.S. Attorney Jeanine Pirro and criticized by a federal judge as unsupported by evidence, had been viewed as part of broader efforts by the Trump administration to pressure the Fed to slash interest rates more aggressively. With the case now handed off to the Fed’s inspector general, Senator Thom Tillis has indicated he is prepared to advance Warsh’s nomination, even as Democrats question Warsh’s independence from Trump and his transparency on financial holdings. Powell, whose term as chair ends May 15 but whose separate term as a Fed governor runs to 2028, has said he would not step down from the board until the investigation was resolved, raising the possibility he could remain in place and limit Trump’s ability to further reshape the central bank. For more information, click here.
On April 24, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2026-16 announcing a notice of proposed rulemaking to streamline certain regulations under 12 CFR parts 24, 43, and 128, consistent with Executive Order 14219 on “Department of Government Efficiency” deregulation. The proposal would rescind or amend provisions the OCC views as unnecessary, unduly burdensome, or unsupported by clear statutory authority, including removing certain references to minority- and women-owned entities in the public welfare investment rules, rescinding the credit risk retention requirements for open market collateralized loan obligations in 12 CFR 43.9, and eliminating duplicative nondiscrimination requirements for federal savings associations. Comments will be accepted for 30 days after publication in the Federal Register. For more information, click here.
On April 24, the Commodity Futures Trading Commission (CFTC) and the U.S. Securities and Exchange Commission (SEC) (collectively, the agencies) jointly proposed extensive amendments to Form PF that would significantly reduce private fund reporting burdens while maintaining core data for systemic risk monitoring, including by raising the general Form PF filing threshold from $150 million to $1 billion in private fund assets and increasing the “large hedge fund adviser” threshold from $1.5 billion to $10 billion. The proposal would eliminate or streamline a range of detailed reporting items — such as certain look‑through, trading and clearing, volatility, turnover, counterparty, and rehypothecation schedules, as well as the private equity “event” reporting section and several large‑hedge‑fund current‑reporting triggers — and simplify industry concentration and trading‑vehicle requirements so that advisers can rely more on internal methodologies and less on prescriptive calculations. The agencies state that, even with fewer filers and fewer data points, Form PF would continue to capture the vast majority of private fund assets and key information needed by the Financial Stability Oversight Council and the agencies to assess systemic risk and investor protection issues. Comments on the proposal are due June 23, 2026. For more information, click here.
On April 24, the European Central Bank announced that it had signed agreements with three European standard-setting bodies — European Card Payment Cooperation (ECPC), nexo standards, and the Berlin Group — to reuse their existing open technical standards for processing digital euro online payments, aiming to minimize implementation costs, promote interoperability, and enable broader geographic reach and new use cases for European payment solutions. By leveraging standards that support contactless tap‑to‑pay, merchant-acquirer connectivity, alias‑based payments (e.g., via phone numbers), and mobile app‑based acceptance, the ECB seeks to reduce Europe’s reliance on proprietary global card and wallet standards and create a uniform digital euro user experience across the euro area. The ECB emphasized that the full benefits of these standards will materialize once EU co‑legislators adopt the digital euro regulation — establishing the digital euro as legal tender — which would give payment providers and merchants greater certainty to invest, innovate, and scale cross‑border solutions ahead of any eventual issuance. For more information, click here.
On April 23, the OCC, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (FDIC) issued a final rule revising the Community Bank Leverage Ratio (CBLR) framework to encourage greater use by qualifying community banks with less than $10 billion in assets. The rule lowers the CBLR requirement from 9% to 8%, extends the grace period for falling below the CBLR from two to four quarters, and caps use of the grace period at eight of the prior 20 quarters. By easing entry and transition requirements while preserving strong capital standards, the agencies aim to expand adoption of the simplified CBLR regime and give participating community banks more capacity to support lending in their local markets. For more information, click here.
On April 23, the BIS’s Financial Stability Institute published an Occasional Paper analyzing how large cryptoasset service providers have evolved into multifunction cryptoasset intermediaries (MCIs) offering bank‑like products such as “earn” programs, margin and secured lending, derivatives, and token issuance, thereby taking on credit, liquidity, and maturity risks without the prudential safeguards that apply to traditional intermediaries. Based on a review of major MCIs’ terms and conditions and interviews with firms and authorities, the paper finds that “earn” products can create deposit‑like, short‑term liabilities, margin and derivatives activity amplify market and counterparty risk, and transparency is often limited, with many MCIs not publishing financial statements. The authors warn that the failures of Celsius and FTX and the October 2025 crypto flash crash illustrate how these vulnerabilities can propagate, particularly as MCIs deepen links with traditional finance, and recommend comprehensive policy responses that subject intermediation‑active MCIs to capital and liquidity requirements, governance and risk‑management standards, and stress testing, using a mix of entity‑based and activity‑based regulation coordinated across borders. For more information, click here.
On April 23, the Administrative Office of the U.S. Courts reported that total bankruptcy filings for the 12-month period ending March 31, 2026, rose 11.9% to 591,850 cases, up from 529,080 in the prior year, with business filings increasing 11.4% (from 23,309 to 25,960) and non-business filings rising 11.9% (from 505,771 to 565,890). While filings have now increased each quarter since reaching a low of 380,634 in June 2022, they remain well below the peak of nearly 1.6 million cases in 2010, and the latest data show Chapter 7 and Chapter 13 cases continuing to dominate individual debtor filings. For more information, click here.
On April 22, the Consumer Financial Protection Bureau (CFPB) issued its final rewrite of Subpart A of Regulation B (Reg B) under the Equal Credit Opportunity Act (ECOA), which eliminates disparate impact from enforcement of ECOA, clarifies the prohibition on discouraging prospective applicants (the rule focuses on statements reflecting an intent to discriminate rather than prior interpretations based on consumer perception or indirect outcomes), and establishes new restrictions on special purpose credit programs (substantially restricts what for-profit creditors can do, especially where eligibility is tied to protected characteristics). The bureau has largely finalized the rule as proposed, with only clarifying edits rather than substantive revisions. Notably, the bureau did so after receiving approximately 64,500 comments on the proposal from industry, consumer advocates, state attorneys general, and members of Congress. The rule will become effective 90 days after publication in the Federal Register.For more information, click here.
On April 22, the CFPB published a report titled Debt Burdens Among Credit-Linked Consumers in the United States, using de-identified credit record data to construct a household-like unit of “credit-linked consumers” who share one or more credit accounts and to compare their outcomes with those of unlinked individuals. The report finds that roughly 38% of consumers with a credit record are credit-linked, that more than half of consumers with mortgages and about a third with credit cards share those obligations, and that many credit-linked consumers share multiple products, such as both mortgages and credit cards. When viewed at the credit-linked (household-like) level, the burden of certain debts, especially student loans, is more pervasive than individual-level data suggest, because obligations held in one person’s name affect the entire linked unit. Overall, credit-linked consumers tend to have higher credit scores, lower credit card utilization, and lower delinquency rates than unlinked consumers, and these advantages persist even when comparing borrowers who all have mortgages, suggesting that linked status itself is associated with stronger credit profiles and risk-sharing dynamics. For more information, click here.
On April 22, U.S. Secretary of Housing and Urban Development Scott Turner and Federal Housing Finance Agency Director William J. Pulte announced that the Federal Housing Administration, Fannie Mae, and Freddie Mac will adopt two newer credit scoring models — VantageScore 4.0 and FICO 10T — for mortgage underwriting and loan purchases, marking the first major update to government-related mortgage credit scoring in decades. The move, described as advancing implementation of the Credit Score Competition Act of 2018, is intended to increase competition among score providers, reduce costs for homebuyers, and expand access to mortgage credit, particularly for creditworthy borrowers whose profiles, including consistent rent payments, may not have been fully recognized under older scoring systems. For more information, click here.
On April 22, the House Financial Services Subcommittee on National Security, Illicit Finance, and International Financial Institutions held a hearing to evaluate the effectiveness of U.S. sanctions programs and broader illicit finance policy, focusing on whether sanctions are being used strategically, with clear objectives, metrics, and coordination across government lists and agencies. Members pressed Treasury’s Assistant Secretary for Terrorist Financing on sanctions against Iran and Russia, including recent time‑limited oil licenses, the risk of undermining deterrence and fueling adversaries’ war efforts, and the need to better align sanctions with energy market stability and support for allies. The discussion also highlighted growing threats from fraud, cyber‑enabled crime, Chinese money‑laundering networks, and cartel finance, and examined how Treasury is modernizing anti‑money‑laundering rules, crypto and stablecoin oversight, and risk‑based supervision to sharpen sanctions tools, reduce false positives and compliance burdens on smaller banks, and preserve the long‑term credibility of sanctions and the dollar’s reserve status. For more information, click here.
On April 21, U.S. Representatives Young Kim (R-CA) and Sam Liccardo (D-CA) introduced the Payments Access and Consumer Efficiency Act of 2026 (PACE Act). The bill would create an optional federal framework for large state‑regulated payment companies, giving qualifying firms OCC supervision and potential direct access to Federal Reserve payment rails, in exchange for bank‑like prudential and customer‑protection standards. As a proposed bill, the PACE Act will likely be revised through hearings and markups, and its ultimate passage is uncertain. Nevertheless, it signals congressional interest in a national, bank‑like framework for large nonbank payment firms and in clearer rules for their access to payment rails and customer funds. For more information, click here.
On April 21, the U.S. House of Representatives’ Financial Services Committee voted to advance H.R. 941, the Small LENDER Act, which would significantly narrow and delay the ECOA’s small business lending data collection regime adopted under Dodd-Frank § 1071. As approved in committee, the bill would exempt lenders with under $10 billion in assets or fewer than 2,500 small business credit originations in each of the prior two years, push the effective compliance date to June 1, 2031, with a subsequent two‑year penalty-free safe harbor, codify borrowers’ ability to decline providing demographic data (backed by a CFPB model disclosure), pare back the list of mandatory data fields and bar lenders from using visual observation or other non–self‑reported methods to collect demographic information, prohibit the CFPB from treating low response rates as evidence of noncompliance, and tighten the definition of “small business” to firms with $1 million or less in annual revenue (down from the bureau’s current $5 million threshold). For more information, click here.
On April 21, a joint hearing of two House Homeland Security subcommittees examined how online scams, crypto fraud, and digital extortion by transnational criminal networks have evolved from consumer-protection issues into top-tier national security threats, draining tens of billions of dollars from American households each year and increasingly intersecting with hostile states, drug cartels, and human trafficking operations. Witnesses described industrial-scale “pig butchering” fraud, ransomware attacks on hospitals and critical infrastructure, business email compromise, and the use of residential proxy networks, cryptocurrency, and AI-driven tools to automate targeting, social engineering, and money laundering at global scale. They emphasized that these networks operate with the discipline and reach of multinational corporations, exploit gaps in U.S. cyber defenses and telecom infrastructure, and in some cases directly fund adversary weapons programs, arguing that only a whole‑of‑government, internationally coordinated response — combining aggressive law enforcement and sanctions with systemic improvements in cybersecurity, information sharing, and victim remediation — can realistically deter and disrupt this growing threat landscape. For more information, click here.
On April 21, the National Credit Union Administration announced the 10th round of proposals under its ongoing Deregulation Project and invited public comment on a rulemaking that would revise its regulations governing conversions and mergers of insured credit unions into banks. The proposal targets provisions in 12 C.F.R. Part 708a, Subpart C, to eliminate outdated newspaper publication mandates, prescriptive disclosure formatting, and “voting guidelines,” remove the regulatory definition of “clear and conspicuous,” and streamline due diligence reporting, with the aim of reducing duplicative and burdensome requirements and giving credit union boards greater flexibility to exercise their fiduciary judgment and design member communications while preserving safety and soundness. Comments must be submitted by June 22. For more information, click here.
On April 20, the DOJ issued an interim final rule extending the compliance dates for its 2024 Americans with Disabilities Act (ADA) Title II website and mobile application accessibility regulations for state and local governments. Large entities now must comply by April 26, 2027, and smaller entities and special districts by April 26, 2028. The substantive requirements of the 2024 rule remain unchanged. DOJ cites resource constraints, staffing limitations, slower-than-expected technological solutions (including limits of generative artificial intelligence for remediation), and litigation risk as reasons for the extension of time. This development is noteworthy for anyone watching the long‑running debate over web accessibility standards, as well as the potential implication of this rulemaking for a future DOJ proposed rule governing public accommodations under Title III of the ADA. For more information, click here.
On April 16, the Federal Trade Commission (FTC) announced that it obtained a temporary restraining order in the U.S. District Court for the Central District of California against NERD Solutions Inc., ED REF Inc., and their principals, Natalie Rodriguez and Pablo Ortiz, alleging they ran a student loan debt relief scheme that misrepresented affiliations with the U.S. Department of Education and loan servicers and falsely promised loan forgiveness in exchange for illegal upfront monthly fees of up to $1,400. The complaint alleges that, since at least February 2022, the defendants cold-called consumers (including many on the National Do Not Call Registry), collected at least $8.8 million from already heavily indebted borrowers, and violated the FTC Act, the Telemarketing Sales Rule, the FTC’s Impersonation Rule, and the Gramm-Leach-Bliley Act, with the case now proceeding in court following a unanimous 2-0 commission vote to file. For more information, click here.
State Activities:
On April 24, the CFTC sued the State of New York in the U.S. District Court for the Southern District of New York, seeking to block New York from applying its gambling laws to CFTC-registered exchanges that list event contracts and prediction markets. The complaint asks for a declaratory judgment that federal law gives the CFTC exclusive authority over such contracts and for a permanent injunction preventing New York from enforcing preempted state laws against CFTC registrants. Framing New York’s enforcement efforts, along with similar actions by other states, as an “onslaught” that threatens Americans’ access to event contracts, CFTC Chairman Michael S. Selig said the agency will not allow state governments to undermine its longstanding jurisdiction. The lawsuit continues the CFTC’s broader campaign to affirm its exclusive authority over prediction markets, following similar cases brought against Arizona, Connecticut, and Illinois. For more information, click here.
On April 24, the OCC issued an interim final rule and an interim final order clarifying that, under longstanding federal law, national banks and federal savings associations may charge certain fees in connection with payment card activities regardless of whether those fees are set by the bank or a third party, and confirming that federal law preempts Illinois’s Interchange Fee Prohibition Act (effective July 1, 2026). The OCC concluded that the Illinois law would create a complex, unworkable, and destabilizing regime for OCC-regulated banks and payment card systems, and expressly declared that national banks and federal savings associations are neither subject to nor required to comply with it, while emphasizing that these actions do not alter the applicability of other existing or future federal laws governing payment card activities, including interchange fees. For more information, click here.
On April 22, Virginia Governor Abigail Spanberger approved HB379, amending the Virginia Residential Landlord and Tenant Act to require landlords, before requesting or collecting any payment or information from a prospective tenant, to disclose in writing or via an accessible posting the amount and refundability of any application fees or deposits, the tenant selection criteria, any automatic or potential grounds for denial, and the identity of any consumer reporting agency used, along with the applicant’s right to a free copy of any consumer report and to dispute its accuracy. The law also clarifies rules on application deposits and caps application fees while requiring landlords to consider documentation of family abuse to mitigate the impact of a low credit score, with the substantive provisions scheduled to take effect July 1, 2027. For more information, click here.
On April 14, Maryland Governor Wes Moore signed House Bill 118, amending the Maryland Money Transmission Act’s definition of “money transmitter” to exclude certain payroll processors acting as an agent of a payor, so long as there is a written agreement authorizing the agent to provide payroll processing services on the payor’s behalf, the payor holds the agent out to employees and other payees as providing those services for the payor, and the payor’s payment obligation to employees and other payees is not extinguished if the agent fails to remit funds. The change clarifies that qualifying payroll processors need not obtain a money transmitter license under state law, and the act takes effect October 1, 2026. For more information, click here.
On April 14, the Vermont Department of Financial Regulation issued a revised Securities Bulletin (S‑2025‑02) providing detailed guidance to investment advisers and broker‑dealers on complying with the Vermont Securities Regulations’ “Privacy Rule,” which governs the protection of clients’ nonpublic personal financial (and certain health) information. The bulletin explains which firms and personnel are covered, defines key terms like “consumer” and “customer,” and outlines when and how firms must deliver clear, conspicuous privacy notices and obtain affirmative opt‑in consent before sharing nonpublic personal information with unaffiliated third parties — requirements that are stricter than the federal opt‑out regime. It also clarifies permissible data sharing without consent (e.g., for transaction processing, fraud prevention, or certain service‑provider and joint marketing arrangements), limits on re‑disclosure of received information, and use of model clauses, emphasizing that the April 14, 2026, revision primarily updates references to the newly effective Vermont Securities Regulations without changing substantive obligations. For more information, click here.
On April 13, Kentucky and Virginia each enacted comprehensive statutes to regulate virtual currency kiosk operators as part of broader digital asset oversight, requiring operators to be licensed, bonded, and subject to ongoing reporting, examination, and capital requirements while imposing detailed consumer protection and anti-fraud obligations. Kentucky’s new Subtitle 13 of KRS Chapter 286 establishes a full licensing framework for “virtual currency kiosk business,” including definitions, exemptions for banks and certain regulated entities, application and change-of-control standards, minimum bond and net-worth thresholds, recordkeeping, permissible investment requirements, transaction caps and waiting periods for new users, mandatory warning notices and live customer service, and strict contractual, trust, and remittance rules for agents. Virginia’s new Chapter 22.2 of Title 6.2 likewise requires kiosk operators to be licensed by the State Corporation Commission, post a surety bond, file annual and quarterly reports (including complaint and suspicious activity data), maintain books and records, and comply with transaction limits, maximum fee caps, robust disclosures about virtual currency risks and scam red flags, and written anti-fraud and anti-money laundering policies that must incorporate blockchain analytics and tracing software; violations are enforceable through license suspension or revocation, cease‑and‑desist orders, civil penalties, attorney general actions, and treatment as prohibited practices under the Virginia Consumer Protection Act, with both regimes phasing in over 2026–2027. For more information, click here and here.