All in Regulatory Update

CFPB Requests Court to Vacate Medical Debt Rule

Adam Witmer
Regulatory Update

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. 

CFPB Says Enforcement of Section 1071 Not a Priority

Adam Witmer
Regulatory Update, Regulation B

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. 

California DFPI Issues Consent Order Against Hatch Bank for AML/CFT Program Deficiencies

Adam Witmer
Regulatory Update, BSA

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.

Appeals Panel Partially Lifts CFPB Layoff Order

Adam Witmer
Regulatory Update

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. 

Judge Blocks FinCEN’s Southwest Border GTO

Adam Witmer
Regulatory Update

On April 24, 2025, the San Diego Union-Tribune reported that a San Diego Judge blocked the FinCEN order to require money services businesses to report transactions above $200 but not more than $10,000, but only in seven San Diego County ZIP codes. On March 11, 2025, FinCEN issued the notice 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. 

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