Ronald K. Vaske

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In a move viewed favorably by FDIC-regulated institutions, the FDIC has approved amendments to the agency’s Guidelines for Appeals of Material Supervisory Determinations that were proposed back in July of 2025. A new supervisory appeals office will now establish review panels that include someone with bank supervisory experience and someone with industry experience.… Continue Reading

In a Truth Social post, President Trump backed a bill called the Credit Card Competition Act (sometimes called the Durbin-Marshall credit card mandate), saying it will help put an end to what he calls “out-of-control swipe fee rip-offs.” Swipe fees — more formally known as interchange fees — are the charges merchants pay every time a customer pays with a credit card.… Continue Reading

On January 9, 2026, President Donald Trump announced via Truth Social that he supports a temporary 10% cap on credit card interest rates (a concept raised during his 2024 presidential campaign), beginning on January 20, 2026. He described the proposal as an effort to address high credit card APRs and improve affordability for consumers.… Continue Reading

On November 10, 2025, the U.S. Court of Appeals for the Tenth Circuit, in a 2–1 decision, issued its opinion in National Association of Industrial Bankers et al. v. Weiser. 

In resolving what it described as “an issue of first impression,” the court held that Section 27 of the Federal Deposit Insurance Act (FDIA) does not preempt the interest rate limitations imposed on state banks by a state that has elected to exercise its right under Section 525 of the Depository Institutions Deregulation and Monetary Control Act of 1980 (DIDMCA) to opt-out of Section 27 with respect to “loans made in such State.” Section… Continue Reading

A federal judge has issued an injunction delaying the compliance dates of the CFPB’s open banking rule (“Rule”).

In issuing the injunction, U.S. District Judge Danny C. Reeves of the U.S. District Court for the Eastern District of Kentucky said the bureau has said it is rewriting the Rule that was issued during the Biden Administration.… Continue Reading

The CFPB has issued an interpretive rule that says the federal Fair Credit Reporting Act (FCRA) preempts states from regulating broad areas of credit reporting.  

“Congress meant to occupy the field of consumer reporting and displace [state] laws within that field,” the bureau said, in the rule that went into effect on October 28.… Continue Reading

The NCUA has issued a Notice of Proposed Rulemaking to codify the elimination of reputational risk from its supervisory program, becoming the latest federal financial regulator to do so.

“NCUA has determined that assessing reputation risk is subjective, ambiguous, and lacking in measurable criteria,” the agency said, in announcing the action.… Continue Reading

The FDIC and the OCC have issued a Notice of Proposed Rulemaking that seeks to establish a standard definition for what constitutes an “unsafe or unsound practice.”

“Too often, examiners focus on a litany of process-related items that are unrelated to a bank’s current or future financial condition,” Acting FDIC Chairman Travis Hill said, in a statement outlining the NPRM, which was unanimously adopted by the agency board. … Continue Reading

The FDIC and the OCC have approved the joint publication of a Notice of Proposed Rulemaking that would codify the removal of reputational risk from their supervisory programs.

“Examining for reputation risk can result in agency examiners implicitly or explicitly encouraging institutions to restrict access to banking services on the basis of examiners’ personal views of a group’s or individual’s political, social, cultural, or religious views or beliefs, constitutionally protected speech, or politically disfavored but lawful business activities,” the FDIC staff said, in a memo.… Continue Reading

HERE IS A LINK TO OUR SPECIAL PODCAST SHOW ABOUT THIS CASE AND ITS ENORMOUS IMPLICATIONS RELEASED ON WEDNESDAY, OCTOBER 1.

On September 22, 2025, a panel of the First Circuit Court of Appeals issued a significant opinion in Conti v. Citizens Bank, N.A., holding unanimously that the National Bank Act does not preempt a Rhode Island statute requiring mortgage lenders to pay interest on mortgage escrow accounts.… Continue Reading