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.
OCC and FDIC Issue Reputational Risk Final Rule
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.
Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – April 8, 2026
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 4, the International Monetary Fund warned that the rapid move to tokenized finance such as shifting stocks, bonds, cash, and other
Treasury Proposes GENIUS Act Principles for Acceptable State Stablecoin Regimes
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.
Tenth Circuit Grants En Banc Rehearing in Colorado DIDMCA Opt-Out Case, Vacating Prior Panel Decision
The Tenth Circuit has granted rehearing en banc in National Association of Industrial Bankers v. Weiser, vacating its November 10, 2025, panel decision that had allowed Colorado to apply its Uniform Consumer Credit Code (UCCC) interest-rate caps to loans made by out-of-state, state-chartered banks to Colorado borrowers. The court’s prior judgment is vacated, issuance of the mandate is stayed, and the case is reopened for en banc consideration. As a result, the panel opinion narrowing DIDMCA preemption no longer reflects the current state of the law in the Tenth Circuit, and the scope of Colorado’s opt-out authority is once again unsettled.
FTC Warning Letters Signal Continued Federal Focus on Debanking and Financial Access
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.
Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – April 1, 2026
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 March 30, the U.S. Department of Labor’s Employee Benefits Security Administration issued a landmark proposed rule that would “democratize”
Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – March 26, 2026
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.
Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – March 17, 2026
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.
Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – March 10, 2026
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.