Aug 4
Aug 4 Fed Allows Alternative Method for Collecting Certain Customer Identification Information

On July 31, 2025, the Federal Reserve Board joined other federal financial institution regulatory agencies, as well as FinCEN, in providing banks the flexibility to use an alternative method for collecting certain customer identification information. Specifically, the agencies now permit banks and credit unions to obtain a tax identification number from a third party, rather than directly from the customer.

Jul 30
Jul 30 CFPB Announces Plans to Revise the Personal Financial Data Rights Final Rule

Adam Witmer

Regulatory Update

On July 29, 2025, the PYMNTS reported that the CFPB asked a judge to stay a lawsuit challenging the open banking rule implemented last year by the Bureau’s previous leadership under the Biden administration. On October 22, 2024, the CFPB issued the Personal Financial Data Rights Final Rule that will give consumers greater rights, privacy, and security over their personal financial data.

Jul 29
Jul 29 Community Groups File Lawsuit Asking CFPB to Implement Section 1071 Rule

Adam Witmer

Regulatory Update, Regulation B

On July 25, 2025, the Ballard Spahr reported that a number of community groups filed a complaint with the U.S. District Court for the District of Columbia against Acting CFPB Director Russell Vought and the CFPB seeking to force the agency to implement the section 1071 rule. The community groups that filed the lawsuit include Rise Economy, fka California Reinvestment Coalition (Rise), the National Reinvestment Coalition (NCRC), the Main Street Alliance (MSA) and Reshonda Young.

Jul 28
Jul 28 Federal Court Reinstates Dismissed NCUA Board Members

Adam Witmer

Regulatory Update

On July 23, 2025, the ABA Banking Journal reported that a federal court ruled that the firings of two former NCUA board members by President Trump were unlawful and therefore both individuals can remain on the board. Trump removed Todd Harper and Tanya Otsuka in April from the NCUA board despite both having several years left in their board terms.

Jul 28
Jul 28 CFPB Reaches Settlement with FirstCash, Inc. for Military Lending Act Violations

Adam Witmer

MLA, Regulatory Update

On July 11, 2025, the CFPB and FirstCash, Inc., along with its nineteen subsidiaries, resolved the November 12, 2021 lawsuit alleging FirstCash of violations of the Military Lending Act (MLA). The parties jointly filed a stipulated final judgment and proposed order, which the court promptly entered the same day.

Jul 22
Jul 22 Agencies Seek Further Comment on Interagency Effort to Reduce Regulatory Burden

Adam Witmer

Regulatory Update

On July 21, 2025, the federal bank regulatory agencies announced their fourth notice requesting public comment to reduce regulatory burden. The Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA) requires the agencies to review their regulations at least once every 10 years to identify outdated, unnecessary, or unduly burdensome regulatory requirements for their supervised institutions.

Jul 22
Jul 22 FinCEN Postpones the Implementation of the Investment Adviser Rule

Adam Witmer

Regulatory Update, BSA

On July 21, 2025, FinCEN announced it intention to postpone the effective date of the final rule establishing Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers (IA AML Rule). The action, according to FinCEN, is to ensure efficient regulation that appropriately balances costs and benefits.

Jul 17
Jul 17 FDIC Proposes Adjustments to Regulatory Thresholds for Inflation

Adam Witmer

Regulatory Update

On July 15, 2025, the FDIC issued a notice of proposed rulemaking that would update certain regulatory thresholds to reflect historical inflation, including those under 12 CFR part 363 related to annual independent audit and reporting requirements, and adjust those thresholds in the future based on a proposed indexing methodology. According to the FDIC’s press release, the proposal is the first of a multi-phase effort to reevaluate thresholds within the FDIC’s regulations.

Jul 16
Jul 16 Court Vacates Medical Debt Rule

Adam Witmer

Regulatory Update

On July 14, 2025, the ABA Banking Journal reported that a federal court in Texas vacated the CFPB’s medical debt reporting rule after the bureau’s current leadership joined with plaintiffs in asking it to be struck down. On January 7, 2025, the CFPB issued the final rule that bans the inclusion of medical bills on credit reports used by lenders and prohibits lenders from using medical information in their lending decisions.

Jul 16
Jul 16 OCC Removes References to Disparate Impact from the Comptroller’s Handbook

Adam Witmer

Regulatory Update, Fair Lending

On July 14, 2025, the OCC announced that it has removed references to supervising banks for disparate impact liability from the “Fair Lending” booklet of the Comptroller’s Handbook and has started removing references in other issuances. Concurrently, the OCC has instructed its examiners that they should no longer examine for disparate impact.