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On April 22, the Consumer Financial Protection Bureau (CFPB or Bureau) 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, and establishes new restrictions on special purpose credit programs (SPCPs). 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.

On March 13, the Consumer Financial Protection Bureau (CFPB or Bureau) released its draft Strategic Plan for FY 2026–2030 and accepted public comment through April 17. The plan, required under the Government Performance and Results Act, sets the Bureau’s mission and priorities for the next four years and explicitly aligns the CFPB’s regulatory strategy with President Trump’s pro‑growth, deregulatory agenda.

On April 17, the Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Federal Reserve), and Federal Deposit Insurance Corporation (FDIC) (collectively, the federal agencies) issued revised interagency guidance on model risk management. The guidance updates and consolidates supervisory expectations for how banks manage the growing use of models across their businesses and effectively manage those risks, while rescinding prior guidance issued by each agency. The updated guidance is principles-based and risk-based, rather than prescriptive, and the federal banking agencies emphasize that model risk management should be tailored to a bank’s model risk profile, as well as the size and complexity of its operations. The agencies further state that non-compliance with the guidance itself will not, standing alone, result in supervisory criticism. That said, weak model risk management can still lead to findings of unsafe or unsound practices or violations of law.

Delaware is positioning itself at the center of digital asset and stablecoin innovation with a coordinated package of legislation aimed at modernizing its banking code and creating a comprehensive framework for payment stablecoins. Senate Bill 16, the “Delaware Banking Modernization Act of 2026,” (SB 16) and Senate Bill 19, the “Delaware Payment Stablecoin Act,” (SB 19) were introduced on March 23, 2026, and are currently moving through the General Assembly. If enacted, both measures would take effect immediately, with implementation required by the earlier of one year after enactment or the issuance of final regulations by the State Bank Commissioner.

As reported by Law360, the U.S. Department of Justice (DOJ) has decided to move forward with its $68 million settlement with Colony Ridge Development LLC without seeking court approval or ongoing judicial oversight. The settlement at issue (discussed here) resolves DOJ and Texas reverse redlining and predatory lending claims in exchange for extensive operational reforms and $48 million in infrastructure improvements plus $20 million in law enforcement and public-safety spending, but no civil money penalties or direct monetary relief to borrowers.

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. The law creates a formal regulatory framework for “vehicle financial protection products,” provides that they are not “insurance”, and ties compliance to the state’s retail installment and consumer loan regimes. Most vehicle financial protection provisions apply to products that become effective on or after January 1, 2027.

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…