The Federal Trade Commission recently issued a proposed policy statement that could reshape how financial services firms use AI-powered tools. The proposed statement, titled “Proposed Policy Statement Concerning the Suppression of Accuracy in Artificial Intelligence Systems,” puts AI developers on notice that altering AI outputs away from accuracy, even if done to comply with a state law, may constitute consumer deception under Section 5 of the FTC Act.… Continue Reading
Aja D. Finger
CFPB Policy Update: Key Takeaways from A Discussion with Senior Advisor and Counsel to the Director, Elie Greenbaum
On June 25, 2026, DC-based Women in Housing & Finance hosted Senior Advisor and Counsel to the Director of the Consumer Financial Protection Bureau, Elie Greenbaum, for a wide-ranging discussion on the Bureau’s current policy priorities and regulatory outlook. Following are notable updates on the CFPB’s agenda for industry participants. This report is based on the input of several members of our Consumer Financial Services Group who attended the meeting. … Continue Reading
CFPB Finalizes Revised 1071 Rule
On May 1, 2026, the CPFB published in the Federal Register the revised Small Business Data Collection Rule, or “1071 Rule” (the “2026 Final Rule”), which it had proposed revising in November 2025. The 2026 Final Rule becomes effective June 30, 2026, although as discussed below, the compliance date is January 1, 2028.… Continue Reading
CFPB Seeks Comments On Raising ‘Larger Participant’ Thresholds
On August 8, 2025, the Consumer Financial Protection Bureau (“CFPB”) issued four advance notices of proposed rulemaking (“ANPR”) inviting comments on whether it should substantially reduce the number of nonbank companies the CFPB supervises in the auto finance, international money transfer, debt collection, and consumer credit reporting markets. An agency spokesperson told Law 360, “As part of President Trump’s overhaul of this abusive agency, ‘Larger Participant’ regulations are open for re-examining after more than a decade.… Continue Reading
AI in the Financial Services Industry
The recent American Association of Residential Mortgage Regulators Annual Conference included a presentation highlighting the rising use of Artificial Intelligence (“AI”) in the Financial Services industry. As this will clearly be an ongoing focus of all regulators, not just residential mortgage regulators, we thought a short summary of the presentation, and some or our reactions to the presentation, might be of interest.… Continue Reading
Regulatory Requirements Related to Adverse Action Notifications
As part of the Federal Reserve Board’s Outlook Live Webinar series, on July 17, 2025, examiners from the Minneapolis and Chicago Federal Reserve Banks hosted a webinar to discuss the regulatory requirements related to adverse action notifications under the Equal Credit Opportunity Act (ECOA), as implemented by Regulation B, and the Fair Credit Reporting Act (FCRA).… Continue Reading