On September 8, 2025, the FDIC updated chapter four of its Formal and Informal Enforcement Actions Manual, entitled Cease-and-Desist Actions, regarding the agency’s minimum standards for terminating cease-and-desist and consent orders issued under Section 8(b) of the Federal Deposit Insurance Act. The manual provides direction for professional staff related to the work necessary to pursue formal and informal enforcement actions.

Sep 15
Sep 15 OCC Takes Action to Depoliticize the Federal Banking System

Adam Witmer

Regulatory Update

On September 8, 2025, the OCC announced actions to eliminate politicized or unlawful debanking in the federal banking system. This initiative aligns with the President’s Executive Order 14331, “Guaranteeing Fair Banking For All Americans,” emphasizing that banks should offer financial services based on objective, individualized, and risk-based assessments.

Sep 10
Sep 10 Agencies Set Third Public Outreach Meeting to Review Regulations

Adam Witmer

Regulatory Update

On September 9, 2025, federal bank regulatory agencies announced that it will hold a hybrid public outreach meeting on October 30, 2025, in Kansas City, Missouri, as part of their review of regulations. This is their third public outreach meeting to identify any outdated or otherwise unnecessary regulatory requirements in their regulations as required by the EGRPRA.

Sep 9
Sep 9 FinCEN Issues Notice on Financially Motivated Sextortion

Adam Witmer

BSA, Regulatory Update

On September 8, 2025, FinCEN issued a Notice to help financial institutions detect and disrupt financially motivated sextortion. According to FinCEN, financially motivated sextortion has been an increasingly common typology and has devastating effects on victims and their families.

Sep 9
Sep 9 FinCEN Modifies Southwest Border GTO

Adam Witmer

BSA, Regulatory Update

On September 8, 2025, FinCEN reiisued a modified Geographic Targeting Order (GTO) to combat illicit cartel and other criminal activity, including money laundering, along the southwest border of the United States. FinCEN previously issued a notice of a GTO requiring certain money services businesses along the southwest border 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.

Sep 8
Sep 8 President Signs Homebuyers Privacy Protection Act

Adam Witmer

Regulatory Update

On September 5, 2025, the President signed into law the “Homebuyers Privacy Protection Act”. The Act prohibits a credit reporting agency from providing a consumer’s credit report to another in connection with a residential mortgage transaction, except for certain circumstances.

Sep 8
Sep 8 FinCEN Issues Guidance on Cross-Border Information Sharing

Adam Witmer

BSA, Regulatory Update

On September 5, 2025, FinCEN issued guidance to encourage and promote appropriate, voluntary cross-border sharing of information between and among financial institutions, including appropriate foreign financial institutions. According to FinCEN, the Guidance aims to help combat the threats posed by money laundering, terrorist financing, and other illicit finance activity, including from drug trafficking organizations, foreign terrorist organizations, and fraudsters.

Sep 8
Sep 8 NCUA Removes Disparate Impact References From Its Manuals

Adam Witmer

Regulatory Update, Fair Lending

On September 4, 2025, the NCUA announced its removal of all references to disparate impact liability from its Fair Lending Guide and other issuances. These updates are in line with the White House Executive Order 14281, which aims to restore equality of opportunity and meritocracy by directing federal agencies to remove the use of disparate impact liability across all contexts.

Sep 3
Sep 3 FDIC Removes Disparate Impact from the Consumer Compliance Examination Manual

Adam Witmer

Regulatory Update, Fair Lending

On August 29, 2025, the FDIC updated sections of the Consumer Compliance Examination Manual. The manual was updated to reflect that the FDIC will evaluate potential discrimination under the Equal Credit Opportunity Act and Fair Housing Act only through evidence of disparate treatment.

Sep 2
Sep 2 Fed Special Fraud Issue of the Consumer Compliance Outlook

Adam Witmer

Regulatory Update

The Federal Reserve Board has recently published a special edition of the Consumer Compliance Outlook focusing on fraud. The special issue discusses several fraud topics, including the banking agencies’ recent request for information on payment and check fraud.

Sep 15
Sep 15 FDIC Revises Enforcement Actions Manual on Cease-and-Desist Terminations

Sep 15
Sep 15 OCC Takes Action to Depoliticize the Federal Banking System

Sep 10
Sep 10 Agencies Set Third Public Outreach Meeting to Review Regulations

Sep 9
Sep 9 FinCEN Issues Notice on Financially Motivated Sextortion

Sep 9
Sep 9 FinCEN Modifies Southwest Border GTO

Sep 8
Sep 8 President Signs Homebuyers Privacy Protection Act

Sep 8
Sep 8 FinCEN Issues Guidance on Cross-Border Information Sharing

Sep 8
Sep 8 NCUA Removes Disparate Impact References From Its Manuals

Sep 3
Sep 3 FDIC Removes Disparate Impact from the Consumer Compliance Examination Manual

Sep 2
Sep 2 Fed Special Fraud Issue of the Consumer Compliance Outlook

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