We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures, consumer financial services providers faced a challenging 2024. Courts across the country issued rulings that will have immediate and lasting impacts on the industry. Our team of more than 170 professionals has prepared this concise, yet thorough analysis of the most important issues and trends throughout our industry. We not only examined what happened in 2024, but also what to expect — and how to prepare — for the months ahead.

On February 11, President Donald Trump nominated Jonathan McKernan to be the new Director of the Consumer Financial Protection Bureau (CFPB or Bureau). If confirmed by the Senate, McKernan will replace Acting CFPB Director Russell Vought, who also serves as the head of the Office of Management and Budget. McKernan was reportedly on the Trump administration’s short list of potential candidates to lead the CFPB and is considered an ally of the financial services industry.

In a recent letter to Andrea Gacki, Director of the Financial Crimes Enforcement Network (FinCEN), Federal Deposit Insurance Corporation (FDIC) Acting Chairman Travis Hill expressed his support for updating the Customer Identification Program (CIP) requirements to better align with modern financial services practices. This initiative is part of Hill’s broader commitment to regulatory reform and innovation, as outlined in his recent policy statements.

The payment stablecoin (PS) legislative endgame is near. There is a clear imperative from the White House to prioritize stablecoin legislation and preserve the U.S. dollar as the world’s reserve currency. Both chambers of Congress are forming a working group to deliver a clear regulatory framework for digital assets. Bipartisan agreement appears within reach.

Today, the U.S. District Court for the Northern District of Texas issued an order in Chamber of Commerce of the United States of America v. Consumer Financial Protection Bureau (CFPB or Bureau) in light of recent changes within the Bureau’s leadership.

On Friday, the U.S. Court of Appeals for the Fifth Circuit ordered the tolling of compliance deadlines for the Consumer Financial Protection Bureau’s (CFPB or Bureau) Small Business Lending Data Collection final rule under Section 1071 of the Dodd-Frank Act (the 1071 Rule). As we previously reported here, the CFPB had asked the appeals court for a pause last Monday to allow the new administration time to consider its position on the 1071 Rule. The CFPB also conveyed that it did not object to the plaintiff trade associations’ earlier motion to toll compliance deadlines, a change-of-position that led to Friday’s order.

In a dramatic series of events, the Consumer Financial Protection Bureau (CFPB or Bureau) has undergone leadership changes, signaling a significant shift in its regulatory approach. These changes began with the firing of Director Rohit Chopra by President Donald Trump and have continued with the resignation of General Counsel Seth Frotman and the appointment of Russell Vought as Acting Director.

This article was republished in insideARM on February 12, 2025.

Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) requested and was granted a 90-day stay in the litigation involving trade associations Cornerstone Credit Union League (Cornerstone) and the Consumer Data Industry Association (CDIA). This case, which challenges the CFPB’s Final Rule on the prohibition of medical debt information in consumer reports, has been temporarily halted as the Bureau undergoes significant leadership changes.

On February 4, the Federal Communications Commission (FCC) proposed a $4,492,500 fine against Telnyx LLC for allegedly allowing illegal robocalls on its network. The FCC’s Notice of Apparent Liability for Forfeiture (NAL) serves as a formal notification of the apparent violations and the proposed monetary penalty. It is not a final Commission action. Telnyx will have the opportunity to respond to the allegations, submit evidence, and present legal arguments before the FCC makes a final determination.