Ronald K. Vaske

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Proposed guidance would require specific elements in bank policies and programs and could give added significance to FDIC’s proposed industry standard-setting organization

Executive Summary

The federal banking agencies have proposed new third-party risk management guidance that is more prescriptive than its emphasis on a “risk-based” approach might suggest. In addition to calling for risk-based oversight, the proposal identifies specific elements that banks should address in board-approved policies and throughout the life cycle of third-party relationships, including due diligence, contracting, ongoing monitoring, documentation, remediation, and termination.… Continue Reading

Executive Summary

The Conference of State Bank Supervisors (CSBS), the nationwide organization representing state banking and financial regulators, has endorsed legislation that would clarify a critical issue concerning the scope of Section 525 of the Depository Institutions Deregulation and Monetary Control Act of 1980 (DIDMCA). The development comes as the House Financial Services Committee prepares to mark up H.R.… Continue Reading

The purpose of this blog is to respond to questions we have received as to why a state like Colorado would ever use Section 525 of DIDMCA to opt out of Section 521 of DIDMCA if it would not preclude rate exportation by out-of-state, state-chartered banks. The question suggests that Congress would not have enacted Section 525 for any purpose other than to prevent rate exportation.… Continue Reading

According to an exclusive Bloomberg Law report, the Federal Deposit Insurance Corporation is considering plans to work with banking and financial technology industry groups to establish a new standard-setting organization. The report is based on a term sheet that would establish a Banking Industry Standards Development Organization (BISDO) to develop standards and issue standard certifications to third-party service providers that partner with banks.… Continue Reading

The Federal Trade Commission (FTC) has taken a major step toward dismantling two theories of discrimination.

In a new Policy Statement Regarding Disparate-Impact Claims and “Unfair Discrimination” Claims, the FTC announces that it will no longer pursue disparate-impact claims under the FTC Act or the Equal Credit Opportunity Act (ECOA). Just as significantly, although less prominently emphasized in the Policy Statement, the FTC has now repudiated its position that the “unfairness” prong of Section 5 of the FTC Act independently authorizes the Commission to pursue discrimination claims.… Continue Reading

The California Department of Financial Protection and Innovation (DFPI) has taken the next step in its challenge to a bank-fintech lending program by appealing the Los Angeles County Superior Court’s decision in Opportunity Financial, LLC v. Hewlett. According to the Superior Court docket, a Notice of Appeal was filed on July 21, 2026, ensuring that the closely watched dispute over the “true lender” doctrine will now move to the California Second Appellate District Court of Appeal. … Continue Reading

Although the Consumer Financial Protection Bureau under Acting Director Russell Vought has withdrawn from defending a number of Biden-era regulatory initiatives, the Bureau appears poised to revisit one of the most controversial issues in consumer credit regulation—credit card late fees.

According to the Office of Information and Regulatory Affairs (OIRA), the CFPB has submitted for interagency review a Request for Information (RFI) regarding “Credit Card Late Fees and Late Payments.”… Continue Reading

A federal judge, at the request of the FTC, recently ordered Cliq Inc., a payment processing company, and its operators to pay $6.5 million for violating a 2015 federal court order intended to prevent the company from assisting in consumer fraud.

U.S. District Court in Nevada entered the order finding Cliq Inc, formerly known as Cardflex Inc.,… Continue Reading

The Aspen Institute’s Financial Security Program has announced a significant new initiative designed to address what many now view as one of the most pressing consumer protection challenges facing the United States: the explosion of fraud and scams targeting American consumers.

The newly launched Scam Prevention Initiative builds upon the work of the Aspen Institute’s National Task Force on Fraud and Scam Prevention and reflects an increasingly broad consensus that scams can no longer be viewed solely as an issue for consumers or financial institutions to solve on their own.… Continue Reading

On June 2, 2026, Professors Todd Zywicki and Thomas Miller, Jr., together with the Center for Individual Freedom, filed an amicus brief in support of the plaintiff trade associations in National Association of Industrial Bankers, et al. v. Weiser, currently pending before the U.S. Court of Appeals for the Tenth Circuit, sitting en banc.… Continue Reading