California has once again expanded its regulation of financial services. On September 30, 2026, Governor Gavin Newsom signed Assembly Bill 2116, which will subject a broad range of commercial financing providers and brokers to licensing, substantive conduct requirements, and regulatory oversight by the California Department of Financial Protection and Innovation (DFPI).… Continue Reading
State Banks
House Financial Services Committee Advances DIDMCA Opt-Out Clarification Bill
By Alan S. Kaplinsky & Burt M. Rublin on
Posted in Fair Lending, State Banks
On September 16, 2026, the House Financial Services Committee (Committee) approved H.R. 7866, the American Lending Fairness Act of 2026, legislation introduced by Rep. Warren Davidson (R-Ohio) and Rep. Andy Barr (R-KY) that would address the effect of state opt-outs under Section 525 of the Depository Institutions Deregulation and Monetary Control Act of 1980 (DIDMCA) on interest-rate exportation by state-chartered banks and credit unions located outside an opt-out state and making loans to a resident of the opt-out state.… Continue Reading
CSBS Releases Artificial Intelligence Supervisory Framework for State Examiners
By Alan S. Kaplinsky, Adam Maarec & John D. Socknat on
The Conference of State Bank Supervisors (CSBS) on September 16, 2026 released an Artificial Intelligence Supervisory Framework designed to help state financial examiners identify and understand how the bank and non-bank institutions they regulate are using artificial intelligence, assess the associated risks, and determine when a more in-depth review may be appropriate.… Continue Reading
CSBS Supports DIDMCA Legislation as House Committee Prepares to Mark Up Bill
Posted in Proposed Rulemaking, State Banks
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
Kraninger Calls for Passage of Legislation Clarifying Section 525 of DIDMCA
By Alan S. Kaplinsky & Burt M. Rublin on
Posted in Proposed Rulemaking, State Banks
Proposed legislation that would clarify the Depository Institutions Deregulation and Monetary Control Act of 1980 (DIDMCA) is important to the health of the dual banking system, Kathleen Kraninger, President and CEO of the Florida Bankers Association, told the House Financial Services Committee at a hearing held on September 2, 2026 entitled “Strengthening the American Economy: Promoting Growth, Opportunity, and Prosperity.”… Continue Reading
House Financial Services Committee to Consider H.R. 7866 and the Intended Scope of DIDMCA’s Opt-Out Provision
By Alan S. Kaplinsky & Burt M. Rublin on
Hearing will focus on whether Section 525 permits an opt-out state to regulate loans made by out-of-state state banks
On Wednesday, September 2, the House Financial Services Committee will hold a hearing entitled “Strengthening the American Economy: Promoting Growth, Opportunity, and Prosperity.” The hearing will begin at 10:00 a.m. ET in Room 2128 of the Rayburn House Office Building.… Continue Reading
DIDMCA’s Section 525 Opt-Out: Congress Allowed States to Reimpose Usury Limits on Their Own Banks, Not on Out-of-State Lenders
By Alan S. Kaplinsky & Ronald K. Vaske on
Posted in State Banks, Usury
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