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FinCEN has published a Notice of Proposed Rulemaking (“NPRM”) that would formalize and expand its whistleblower program, offering potentially substantial financial payouts to whistleblowers reporting certain financial crimes. According to FinCEN’s announcement, this initiative is designed to incentivize and protect individuals who report violations of major financial crime laws—specifically, the Bank Secrecy Act (“BSA”), the International Emergency Economic Powers Act (“IEEPA”), the Trading With the Enemy Act (“TWEA”), and the Foreign Narcotics Kingpin Designation Act (the “Kingpin Act”).… Continue Reading

On March 20, 2026, the White House released its National Policy Framework for Artificial Intelligence. This Framework contains a sweeping set of legislative recommendations intended to establish a coherent, nationally unified approach to AI governance. While the Framework does not itself create binding legal obligations, it is likely to shape federal AI legislation in the months and years ahead.… Continue Reading

Following New York City Mayor Zohran Mamdani’s Executive Orders cracking down on so-called “junk fees” and “subscription traps,” city officials have begun taking action against companies and industries they say abuse consumers by imposing such fees, create such traps or otherwise violate the consumer protection laws under DWCP’s jurisdiction. While most of these actions did not involve consumer financial services as such, we felt it important for our readers to be aware of how aggressive and active this agency has become. … Continue Reading

Effective April 1, 2026, California Senate Bill 22 (SB 22) will now require businesses to provide cash back on gift cards with a balance under $15 (up from $10 under current law) upon a consumer’s request. Given the nearly twenty-year history of plaintiffs’ firms targeting retailers in class actions for failure to comply with California’s current gift card law, businesses should expect that the plaintiffs’ bar will be ready to test compliance with the new threshold shortly after the law takes effect.… Continue Reading

Although an interpretive rule that made Buy Now Pay Later (BNPL) services subject to the Truth in Lending Act has been withdrawn, the issue remains a flashpoint in the industry and among policymakers, according to the Congressional Research Service (CRS).

“Whether BNPL providers should be subject to the Truth in Lending Act (TILA, 15 U.S.C.… Continue Reading

The Federal Reserve is requesting comments on a proposal to remove reputation risk from the supervision of banks it oversees. Comments on the Fed proposal are due April 27, 2026.

“We have heard troubling cases of debanking—where supervisors use concerns about reputation risk to pressure financial institutions to debank customers because of their political views, religious beliefs, or involvement in disfavored but lawful businesses,” Vice Chair for Supervision Michelle W.… Continue Reading

The NCUA board has approved a plan to continue the agency’s temporary 18% rate ceiling for most loans made by federal credit unions.

Section 107(5)(A)(vi)(I) of the Federal Credit Union Act, 12 U.S.C. 1757(5)(A)(vi)(I), limits federal credit unions to a 15% interest rate ceiling on loans but authorizes the NCUA board to increase rates for up to 18 months after certain required consultations and if certain conditions are met.… Continue Reading

We recently blogged about President Trump’s Truth Social post in which he announced his intent to impose a 10% per annum interest rate cap on credit cards for one year beginning on January 20, 2026, the one-year anniversary of his second term of office. On January 21, during his speech delivered at the World Economic Forum in Davos, Switzerland, he announced his support for legislation to accomplish that result.… Continue Reading

Promising that the NCUA will not engage in “regulation by enforcement,” NCUA Chairman Kyle Hauptman has sent a letter to credit unions outlining his supervisory priorities for 2026.

“NCUA is dedicated to supporting credit unions, developing right-sized regulations and policies that safely advance innovation within the credit union system, and protecting member deposits and the Share Insurance Fund through productive, streamlined credit union supervision,” Hauptman wrote in his letter.… Continue Reading