On March 20, 2025, the OCC issued a Bulletin announcing that it has commenced removing references to banks' reputation risk from its Comptroller’s Handbook booklets and guidance issuances. Concurrently, the OCC has instructed its examiners that they should no longer examine for reputation risk.

Mar 27
Mar 27 CFPB Seeks to Overturn Case Against Townstone

Adam Witmer

Fair Lending, Regulatory Update

On March 26, 2025, the CFPB announced that it is seeking to vacate the settlement the CFPB extracted from Townstone back in 2024 after suing the nonbank retail-mortgage creditor for discriminatory lending practices and redlining. In its press release, the CFPB stated that after a thorough review, the Bureau is seeking to “make Townstone whole by returning the six-figure penalty they were forced to pay.”

Mar 25
Mar 25 FinCEN Publishes FAQs on the Southwest Border GTO

Adam Witmer

Regulatory Update, BSA

On March 24, 2025, FinCEN issued a set of Frequently Asked Questions for the Geographic Targeting Order involving certain money services businesses in California and Texas on the Southwest Border. This is in relation to the March 11 GTO requiring all money services businesses located in 30 ZIP Codes across California and Texas to file additional Currency Transaction Reports (CTRs) with FinCEN for transactions above $200 but not more than $10,000.

Mar 24
Mar 24 FinCEN Removes BOI Reporting Requirements for U.S. Entities

Adam Witmer

BSA, Regulatory Update

On March 21, 2025, FinCEN issued an interim final rule that removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act. Foreign entities that meet the new definition of a “reporting company” and do not qualify for an exemption must report their BOI to FinCEN under new deadlines.

Mar 18
Mar 18 FinCEN Issues GTO Imposing Additional Reporting Requirements Along the Southwest Border

Adam Witmer

Regulatory Update, BSA

On March 11, 2025, FinCEN issued a notice of a Geographic Targeting Order requiring certain money services businesses along the southwest border of the United States to report and retain records of transactions in currency of more than $200 but not more than $10,000, and to verify the identity of persons presenting such transactions. The order will take effect starting April 14, 2025 and ends on September 9, 2025.

Mar 17
Mar 17 OCC Reaffirms That Certain Crypto-Asset Activities Are Permissible

Adam Witmer

Regulatory Update

On March 7, 2025, the OCC issued a letter to reaffirm that a range of cryptocurrency activities are permissible in the federal banking system. Through Interpretive Letter 1183, the OCC confirmed that crypto-asset custody, certain stablecoin activities, and participation in independent node verification networks such as distributed ledger are permissible for national banks and federal savings associations.

Mar 17
Mar 17 Senate Disapproves CFPB’s Rule to Oversee Digital Payment Apps

Adam Witmer

Regulatory Update

On March 5, 2025, the Senate issued a joint resolution (S.J.Res. 28) disapproving the rule submitted by the CFPB relating to “Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications”. The CFPB finalized the rule in November 2024 which aimed to supervise the largest nonbank companies offering digital funds transfer and payment wallet apps.

Mar 6
Mar 6 CFPB Extends Comment Period for Data Rule

Adam Witmer

Regulatory Update

On 3/5/25, the CFPB published in the Federal Register a proposed rule to extend the comment period from the 12/13/24 notice of proposed ruemaking requesting comment on the CFPB’s proposal to amend Regulation V.

Mar 4
Mar 4 FDIC Delays Portion of Official Sign and Advertising Rule

Adam Witmer

Regulatory Update

On 3/3/25, the FDIC announced that it was postponing the compliance date from May 1, 2025 to March 1, 2026 for the requirements under 12 CFR 328.5 related to the display of the FDIC official digital sign on an insured depository institution’s (IDI’s) digital channels, as well as analogous requirements related to IDI’s automated teller machines (ATMs) and like devices under 12 CFR 328.4.

Mar 4
Mar 4 NCUA to Cease Publication of OD/NSF Fee Data

Adam Witmer

Regulatory Update

On 3/3/25, NCUA Chairman, Kyle S. Haptman, announced that the NCUA “will no longer publish overdraft and non-sufficient fund fee income for individual credit unions.” The NCUA will, however, continue to collect the data during supervisory examinations.

Mar 31
Mar 31 OCC Removes Reputation Risk from Bank Examinations

Mar 27
Mar 27 CFPB Seeks to Overturn Case Against Townstone

Mar 25
Mar 25 FinCEN Publishes FAQs on the Southwest Border GTO

Mar 24
Mar 24 FinCEN Removes BOI Reporting Requirements for U.S. Entities

Mar 18
Mar 18 FinCEN Issues GTO Imposing Additional Reporting Requirements Along the Southwest Border

Mar 17
Mar 17 OCC Reaffirms That Certain Crypto-Asset Activities Are Permissible

Mar 17
Mar 17 Senate Disapproves CFPB’s Rule to Oversee Digital Payment Apps

Mar 6
Mar 6 CFPB Extends Comment Period for Data Rule

Mar 4
Mar 4 FDIC Delays Portion of Official Sign and Advertising Rule

Mar 4
Mar 4 NCUA to Cease Publication of OD/NSF Fee Data

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