All in Regulatory Update

On April 5, 2025, the ABA Banking Journal reported that a federal court has vacated the CFPB’s rule on credit card late fees a day after the American Bankers Association and other plaintiffs reached an agreement with the bureau to end a lawsuit over the rule. Under the terms of the settlement with the plaintiffs, the CFPB acknowledged it exceeded its authority under the Credit Card Accountability Responsibility and Disclosure Act, and that the late fee rule violates the Administrative Procedure Act. 

On April 2, 2025, U.S. Secretary of the Treasury Scott Bessent led a public-private partnership event with 16 systemically important global financial institutions and federal law enforcement agencies, focused on denying Iran access to the global financial system. This event is part of FinCEN’s “Iran Maximum Pressure and Counter Terrorism” (or IMPACT) Exchange series. 

On April 9, 2025, FinCEN issued a Financial Trend Analysis focused on patterns and trends identified in BSA data linked to fentanyl-related illicit finance. The BSA data filed between January and December 2024 included 1,246 reports identifying suspected fentanyl-related activity including precursor chemical procurement, fentanyl trafficking, and fentanyl-linked money laundering.

On April 3, 2025, the ABA Banking Journal reported that the CFPB said in a court filing that its leadership has directed staff to initiate new rulemaking to implement Section 1071 of the Dodd-Frank Act and plans to soon release a proposal to possibly replace or change its current rule. The CFPB filed to the District Court for the Southern District of Florida an unopposed motion to stay the section 1071 rule and hold proceedings in abeyance.