All in Regulatory Update

On May 5, 2025, the OCC issued a request for information (RFI) on the key challenges and barriers faced by community banks in the adoption and implementation of digital banking solutions. The OCC said that the RFI will help the OCC better understand the specific obstacles that community banks encounter in their efforts to modernize operations, enhance customer experience, and remain competitive in an increasingly digital financial services environment.

On May 1, 2025, the ABA Banking Journal reported that the CFPB requested a court to vacate the Regulation V rule prohibiting creditors from considering medical information in credit eligibility determinations. The final rule's original implementation date was March 17, 2025, but was stayed until June 15, 2025, after the rule was challenged in federal court by groups representing credit unions and the credit reporting industry. 

On April 30, 2025, the CFPB announced that it will not prioritize enforcement or supervision actions with regard to Section 1071 Rule to entities that are currently outside the stay imposed under Texas Bankers Association v. CFPB lawsuit. According to the CFPB, it will instead keep its enforcement and supervision resources focused on pressing threats to consumers, particularly servicemen and veterans. 

In April 2025, the California Department of Financial Protection and Innovation (DFPI) issued a Consent Order against Hatch Bank requiring its Board of Directors to strengthen its supervision and direction of bank management, and its monitoring of the bank's AML/CFT program. Hatch Bank is a state-chartered, FDIC-insured, Banking as a Service (BaaS) sponsor bank.

On April 29, 2025, the Consumer Finance Monitor reported that the U.S. Circuit Court of Appeals for the District of Columbia has upheld a temporary injunction issued by Judge Amy Berman Jackson of the U.S. District Court for the District of Columbia. On April 18, Judge Jackson issued an order after finding that the CFPB's firings affected more employees than a layoff plan she had tried to stop earlier in the case.