Artificial intelligence is rapidly transforming the consumer financial services industry. From undeArtificial intelligence is rapidly transforming the consumer financial services industry. From underwriting and fraud detection to customer engagement and collections, financial institutions are increasingly deploying advanced AI tools to automate processes, personalize services, and improve operational efficiency. We are releasing today, on our Consumer Finance Monitor Podcast show, a discussion of what may be the next major technological shift for the industry: Agentic AI in Consumer Financial Services — AI systems capable of acting autonomously, making decisions, and interacting directly with consumers.… Continue Reading
Oregon’s DIDMCA Opt-Out Legislation Heads to the Governor’s Desk
As we recently reported, in the wake of the Tenth Circuit’s decision in National Association of Industrial Bankers v. Weiser, 159 F.4th 694 (10th Cir. 2025), Oregon legislators re‑introduced H.B. 4116—legislation designed to opt Oregon out of Section 521 of the Depository Institutions Deregulation and Monetary Control Act of 1980 (DIDMCA).… Continue Reading
OCC Issues Two Final Rules to Reduce Regulatory Burden on Community Banks (National Banks and Federal Savings Associations and Banks)
The Office of the Comptroller of the Currency (OCC) recently adopted two final rules designed to reduce regulatory burden on community banks. The rules expand streamlined licensing procedures for qualifying community banks and rescind an outdated mortgage data collection regulation that applied only to national banks.
According to the OCC, the actions are intended to tailor regulatory requirements to the size and complexity of banking organizations and eliminate duplicative or unnecessary compliance obligations while preserving core supervisory and consumer protection safeguards.… Continue Reading
OCC proposes overhaul of appeals process
Following on the FDIC’s recent issuance of updated guidelines for appeals of material supervisory determination, the OCC is now proposing to replace the existing guidance for handling appeals of material supervisory determinations at institutions under its jurisdiction and to create a board to decide bank appeals. The deadline for comments on the proposal is April 20, 2026.… Continue Reading
New York City Adopts Sweeping SHIELD Debt Collection Rule: How It Differs from Prior DCWP Rules and CFPB Regulation F
As part of his campaign for election, New York City Mayor Zohran Mamdani vowed to make New York City more affordable. To that end and as part of his affordability initiative, he has issued Executive Orders 9 and 10 intended to crack down on “junk fees” and “subscription tricks and traps,” using the New York City Department of Consumer and Worker Protection (DCWP) to implement the initiative.… Continue Reading
Today’s podcast episode: Credit Card Rate Caps and the Credit Card Competition Act: The Right Problem, the Wrong Tools?
We are releasing today on our Consumer Finance Monitor podcast our host Alan Kaplinsky’s discussion with Marisa Calderon, President and CEO of Prosperity Now, about two high-profile policy proposals raised or embraced by President Trump as part of a broader populist affordability agenda:
- A nationwide 10% cap on credit card interest rates for one year.
New York publishes Buy Now, Pay Later Rules
The New York Department of Financial Services has published proposed rules governing Buy Now, Pay Later (BNPL) financing plans operating in the state.
The proposal, among other things, would require BNPL providers to register with the state. The regulations implement a law signed by Governor Kathy Hochul as part of her FY26 budget plan.… Continue Reading
Fed requests comment on plan to remove reputation risk from supervision of banks
The Federal Reserve is requesting comments on a proposal to remove reputation risk from the supervision of banks it oversees. Comments on the Fed proposal are due April 27, 2026.
“We have heard troubling cases of debanking—where supervisors use concerns about reputation risk to pressure financial institutions to debank customers because of their political views, religious beliefs, or involvement in disfavored but lawful businesses,” Vice Chair for Supervision Michelle W.… Continue Reading
D.C. Circuit Hears En Banc Argument in National Treasury Employees Union v. Vought: A Defining Case for the CFPB’s Future
On February 24, 2026, the full United States Court of Appeals for the District of Columbia (consisting of 11 judges sitting en banc) heard oral argument in National Treasury Employees Union v. Vought (No. 25-5091), a case that could prove pivotal not only for the workforce of the Consumer Financial Protection Bureau (CFPB) but also for the scope of presidential authority over independent agencies more broadly.… Continue Reading
California Court Grants Summary Judgment to OppFi, Rejects DFPI “True Lender” Theory
In a very significant and potentially precedent-setting February 24, 2026 decision, the Los Angeles County Superior Court (Hon. Gary D. Roberts) issued a tentative decision granting summary judgment in favor of Opportunity Financial, LLC (“OppFi”) and against the California Department of Financial Protection and Innovation (“DFPI”). The ruling rejects the DFPI’s claim that OppFi was the “true lender” of certain loans originated by Utah-chartered FinWise Bank and therefore subject to California’s 36% interest rate cap under the California Financing Law (CFL), as amended by AB 539.… Continue Reading