All in Regulatory Update

On November 13, 2025, the CFPB  issued a proposed rule that amends provisions related to disparate impact, discouragement of applicants or prospective applicants, and special purpose credit programs under Regulation B, the regulation implementing the Equal Credit Opportunity Act (ECOA). According to the CFPB, the amendments would facilitate compliance with ECOA by clarifying the obligations imposed by the statute.

On November 12, 2025, the OFAC designated the Democratic Karen Benevolent Army (DKBA) and four senior leaders for supporting Burma-based cyber scam centers that target Americans through fraudulent investment schemes. In addition, the OFAC designated three other organizations linked to Chinese organized crime and have worked with the DKBA and other armed groups to develop these scam centers.

On November 4, 2025, the OFAC sanctioned eight individuals and two entities for their role in laundering funds derived from a variety of illicit Democratic People’s Republic of Korea (DPRK) schemes, including cybercrime and information technology (IT) worker fraud. According to the Multilateral Sanctions Monitoring Team’s report, these operations have been linked to the funding for the DPRK’s weapons of mass destruction (WMD) programs and destruction of physical computer equipment.

On October 29, 2025, the ABA Banking Journal reported that a federal court issued an order preventing the CFPB from enforcing its rule on financial data sharing while the bureau reassesses the regulation. The CFPB  finalized the rule in October 2025 that requires financial institutions, credit card issuers, and other financial providers to unlock an individual’s personal financial data and transfer it to another provider at the consumer’s request for free. 

On October 28, 2025, the CFPB published an interpretive rule to clarify that the Fair Credit Reporting Act (FCRA) generally preempts State laws that touch on broad areas of credit reporting, consistent with Congress's intent to create national standards for the credit reporting system. The interpretive rule replaces a July 2022 interpretive rule that the Bureau withdrew in May 2025.

On October 23, 2025, FinCEN published a Financial Trend Analysis (FTA) identifying approximately $9 billion of potential Iranian shadow banking activity that occurred through U.S. correspondent accounts in 2024. The analysis draws on reports from U.S. financial institutions about transactions before the maximum pressure campaign and supplements FinCEN’s June advisory on Iran’s illicit oil smuggling, shadow banking, and weapons procurement activities.