All in Regulatory Update

On August 26, 2025, the CFPB issued a proposed rule adopting a standard definition of “risks to consumers with regard to the offering or provision of consumer financial products or services” that will bind the Bureau in proceedings to designate nonbank covered persons for Bureau supervision. The CFPB stated that this will ensure that the Bureau acts within the bounds of its statutory authority and provide clarity to institutions about the standard it applies.

On August 22, 2025, the CFPB issued an advance notice of proposed rulemaking to inform its consideration of four issues related to the implementation of section 1033 of the Dodd-Frank Act. Section 1033 outlines the requirement for “covered persons” to make financial transaction data available to consumers and authorized third parties upon request, under rules prescribed by the Bureau.

On August 19, 2025, FinCEN extended the effective dates for orders issued on June 25, 2025, prohibiting certain transmittal of funds involving three Mexico-based financial institutions. Covered financial institutions will now have until October 20, 2025, to implement the orders prohibiting certain transmittal of funds involving CIBanco S.A., Institución de Banca Multiple (CIBanco), Intercam Banco S.A., Institución de Banca Multiple (Intercam), and Vector Casa de Bolsa, S.A. de C.V. (Vector).

On August 19, 2025, the FDIC’s Board of Directors approved a proposed rule to amend regulations governing the display of the FDIC official digital sign and non-deposit signage. According to the FDIC’s press release, the proposed changes would simplify requirements for banks’ display of the FDIC official digital sign and non-deposit signage on digital deposit-taking channels, including bank websites, mobile applications, ATMs and like devices.