On December 30, Baltimore Mayor Brandon M. Scott announced that the City of Baltimore filed a civil action against a fintech provider offering small-dollar cash advance products, alleging violations of the Baltimore Consumer Protection Ordinance. According to the City, the fintech’s cash-advance product that was promoted as an earned wage access or overdraft-style service but allegedly imposed costs that far exceeded Maryland’s 33 percent interest-rate cap for consumer loans.
Continue Reading Baltimore Sues Fintech for Alleged Unfair and Deceptive Cash-Advance Practices

On December 30, the U.S. District Court for the District of Columbia ordered that the CFPB must continue requesting funding from the Board of Governors of the Federal Reserve System under the statutory funding framework established by Congress. The Court ruled that the CFPB may not decline to request funding based on its interpretation of the Federal Reserve’s operating losses or an asserted lack of available “combined earnings.” (previously discussed here).
Continue Reading Federal Court Orders CFPB to Continue Requesting Funding Operations Amid Defunding Dispute

On December 19, New York Governor Kathy Hochul signed into law S8416, amending New York’s General Business Law to enact the Fostering Affordability and Integrity Through Reasonable Business Practices Act. The law expands the state’s primary consumer protection statute beyond deceptive acts to also prohibit unfair and abusive business practices.
Continue Reading New York Enacts FAIR Business Practices Act Expanding State Consumer Protection Law

On December 23, the CFPB issued an advisory opinion stating earned wage access products fall outside the definition of credit under TILA’s Regulation Z, withdrawing a Biden-era proposed interpretive rule that identified all such products as credit.
Continue Reading CFPB: Earned Wage Products Are Not Loans Under TILA

On December 8, the Oregon Department of Consumer and Business Services entered into a consent order with two affiliated companies resolving allegations of violations of the Oregon Consumer Finance Act arising from a bank partnership program. According to the regulator, the companies allegedly charged, contracted for, or received interest above Oregon’s statutory limits on hundreds of consumer loans made to Oregon residents, even though the loans were originated and funded by an out-of-state, state-chartered bank.
Continue Reading Oregon Enters $1.56 Million Consent Order Over Alleged Excessive Interest Charges in Bank Partnership Lending Program

On December 15, the Board of Governors of the Federal Reserve System and the CFPB issued joint final rules amending the official interpretations to their regulations implementing the Consumer Leasing Act and the Truth in Lending Act. The amendments reflect the annual inflation adjustment required by statute and increase the exemption thresholds effective January 1, 2026.
Continue Reading CFPB and Federal Reserve Finalize 2026 Inflation Adjustments to Consumer Leasing and Truth in Lending Coverage Thresholds

On December 15, the CFPB issued a final rule amending Regulation V under the Fair Credit Reporting Act to update the maximum amount a consumer reporting agency may charge a consumer for certain file disclosures. The amendment implements FCRA’s annual inflation adjustment requirement and sets the ceiling for calendar year 2026.
Continue Reading CFPB Finalizes 2026 Increase to Fair Credit Reporting Act Disclosure Fee Cap

On December 10, 2025, the National Credit Union Administration announced a new Deregulation Project and issued the first package of proposed rules aimed at streamlining its regulatory framework for federally insured credit unions under the Federal Credit Union Act.
Continue Reading NCUA Launches Deregulation Project and Proposes Four Rules to Streamline Credit Union Regulations

On December 9, FinCEN announced a consent order imposing a $3.5 million civil money penalty on a peer-to-peer virtual asset trading platform, alleging willful violations of the Bank Secrecy Act. FinCEN alleged that the platform’s compliance failures allowed it to process substantial volumes of transactions connected to criminal activity, sanctions exposure, and other high-risk conduct over an extended period.
Continue Reading FinCEN Assesses $3.5 Million Penalty Against Virtual Asset Platform for Alleged BSA Violations

On December 8, the CFTC announced a series of staff actions addressing the use of digital assets and tokenized assets as collateral in regulated derivatives markets. The actions include issuance of staff guidance on tokenized collateral, a staff no-action letter applicable to futures commission merchants, and withdrawal of a prior staff advisory related to virtual currencies held in segregation.
Continue Reading CFTC Rolls Out Digital Asset Collateral Pilot, Issues Tokenized Collateral Guidance, and Withdraws Prior Virtual Currency Advisory

On December 10, in a federal court filing, the CFPB stated that it plans to issue an interim final rule revising its open banking framework under the Dodd Frank Act’s Section 1033. The disclosure came in a status report filed in the Kentucky federal court litigation challenge over the rule that directed banks to make account data available free of charge for consumer sharing with fintechs.
Continue Reading CFPB Signals It Will Issue Interim Open Banking Rule as Funding Lapse Approaches

On November 17, 2025, the SEC’s Division of Examinations released its examination priorities for fiscal year 2026, identifying areas the agency alleges present heightened compliance and investor protection risks under the federal securities laws. The priorities apply to investment advisers, investment companies, broker-dealers, municipal advisors, transfer agents, self-regulatory organizations, clearing agencies, and other registrants overseen by the Division.
Continue Reading SEC Releases 2026 Examination Priorities Highlighting Compliance, Information Security, and Emerging Technology

On December 8, the OCC and the FDIC announced that they are rescinding the 2013 Interagency Guidance on Leveraged Lending and the 2014 FAQs. The agencies explained that banks should instead manage leveraged lending activities under generally applicable safe and sound lending principles, including underwriting, credit administration, and risk rating standards used for other commercial loan portfolios.
Continue Reading OCC and FDIC Withdraw Leveraged Lending Guidance