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On April 7, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (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.

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

Federal Activities:

On April 4, the International Monetary Fund warned that the rapid move to tokenized finance such as shifting stocks, bonds, cash, and other…

The U.S. Department of the Treasury has issued a notice of proposed rulemaking (NPRM) to implement the broad-based principles set out in the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act for determining when a state-level regulatory regime for “state qualified payment stablecoin issuers” is “substantially similar” to the federal regulatory framework. That determination is the gateway for state-chartered, nonbank stablecoin issuers with up to $10 billion in outstanding stablecoins to operate primarily under state oversight rather than as federally supervised “permitted payment stablecoin issuers.” Comments will be due 60 days after publication in the Federal Register.

According to a recent report by WebRecon, court filings under the Telephone Consumer Protection Act (TCPA) were way up for the month. On the other hand, Fair Credit Reporting Act (FCRA) and Fair Debt Collection Practices Act (FDCPA) filings as well as complaints filed with the Consumer Financial Protection Bureau (CFPB) were all down. Nonetheless, everything is still up YTD.

The Federal Trade Commission (FTC) has taken a highly visible step into the national debate over “debanking” by sending warning letters to several large payment networks and financial services providers, reminding them that deplatforming or denying customers access to financial products or services due to political or religious beliefs could violate their existing obligations under Section 5 of the FTC Act. The FTC’s letters signal a sharpened enforcement focus on how financial services firms manage account closures, suspensions, and access to services, particularly when political or religious views are implicated.

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

State Activities

Federal Activities:

On March 30, the U.S. Department of Labor’s Employee Benefits Security Administration issued a landmark proposed rule that would “democratize”…

In a decision of first impression, the Supreme Court of Virginia in Garofalo v. Di Vincenzo, defined what “evident partiality” means under the Virginia Uniform Arbitration Act (VUAA). The court held that a party seeking to vacate an arbitration award must show that a reasonable person, knowing all relevant facts, would conclude the arbitrator’s conduct signifies obvious bias against that party. Applying this standard, the court affirmed confirmation of a FINRA arbitration award and declined to vacate based on an arbitrator’s undisclosed, attenuated prior connections to one side.

Troutman Pepper Locke partner David Anthony and associate Noah DiPasquale co‑authored a recent article for the American Bar Association’s Litigation Section, “Reasonable Reinvestigation, Not Legal Adjudication: CRAs and Furnishers under the FCRA,” together with Jennifer Sarvadi of Hudson Cook. The piece examines how courts nationwide are refining what counts as a “reasonable” investigation under the Fair Credit Reporting Act’s (FCRA) reasonable procedures and reinvestigation provisions, 15 U.S.C. §§ 1681e(b), 1681i, and 1681s‑2(b).