All in Regulatory Update

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.

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. 

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.

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Reduction Act (EGRPRA) requires the agencies to review their regulations at least once every 10 years to identify outdated, unnecessary, or unduly burdensome regulatory requirements for their supervised institutions.

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.

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.

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.