As previously reported, in June 2025 the CFPB issued an interim final rule extending the compliance dates for the section 1071 small business data collection and reporting rule. The CFPB has now issued a final rule with the same extended compliance dates provided for in the June interim final rule.… Continue Reading

Despite President Trump’s efforts to fire her, the Supreme Court has ruled that Lisa D. Cook can remain on the Federal Reserve Board at least until the court hears oral arguments in January 2026.

The administration had asked the Supreme Court for a stay of a preliminary injunction issued by the U.S.… Continue Reading

Contending that the decision of a divided three-judge panel of the U.S. Circuit Court of Appeals for the District of Columbia would lead to a shutdown of the CFPB by the Trump Administration, plaintiffs in a lawsuit challenging proposed Reductions-in-Force at the bureau are asking for an en banc rehearing in the case before all of the active judges of the D.C… Continue Reading

As our regular podcast listeners know, we ordinarily release a new podcast show once each week on Thursday. On a very few occasions, we have released a special extra podcast show during the same week. We have only done that when a development occurs which we feel is of extraordinary importance and time sensitive.… Continue Reading

On September 29, 2025, FinCEN issued a Notice and Request for Comment (the “Notice”) on a proposed information gathering exercise – A Survey of the Costs of Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Compliance (the “Survey”).  Specifically, the Survey is intended to gather information on direct compliance costs incurred by non-bank financial institutions in AML/CFT compliance and, to the extent those costs overlap with other obligations, the amount directly attributable to AML/CFT compliance.… Continue Reading

President Trump correctly removed Lisa D. Cook from the Federal Reserve Board for improperly claiming on mortgage applications that residences in Michigan and Georgia both were her primary residences, the Trump Administration said in a brief filed with the Supreme Court.

“Following the statute, President Trump duly removed respondent Lisa Cook for ‘deceitful and potentially criminal conduct in a financial matter’ that renders her unfit to serve on the Nation’s preeminent financial policymaking and regulatory body—a quintessential cause for removal,” Solicitor General D.… Continue Reading

Last month, New York Attorney General Letitia James sued Early Warning Services, LLC (EWS), the company that operates the Zelle Network, for allegedly failing to protect its users from fraud. The complaint, much of which was filed under seal, claims that EWS harmed consumers by creating “a payment network that was highly susceptible to fraudulent activity, that lacked the basic network safeguards, and that exposed millions of consumers to widespread fraud.”… Continue Reading

Allowing President Trump to fire Lisa D. Cook from the Fed would “signal to the financial markets that the Federal Reserve no longer enjoys its traditional independence, risking chaos and disruption,” Cook told the Supreme Court, in her opposition for a stay in her case.

“For decades, the Board’s insulation from direct presidential control has allowed the American markets and economy to thrive,” she wrote, adding, “the legislative record is abundantly clear that Congress did not mean for Federal Reserve Board governors to serve at the President’s pleasure.”… Continue Reading

The American College is now inviting nominations of outstanding lawyers who have achieved preeminence in consumer financial services law. Nominees must:

  • Have 10+ years of experience practicing consumer financial services law;
  • Have a U.S. consumer financial services law practice;
  • Have achieved preeminence in the field through repeated and substantial contributions (e.g.,
… 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