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NYDFS Refresher Series – Part 1: What Companies Need to Know Ahead of Annual Certifications of Compliance

Upcoming compliance certification Every year by April 15, financial entities subject to the New York Department of Financial Services (NYDFS) oversight (covered entities) are required to certify their compliance with the NYDFS’ cybersecurity regulations, 23 NYCRR Part 500 (Part 500). This year’s deadline will be the first time covered entities must certify compliance with all of the amendments to Part 500 that were phased in …

FTC Issues New Advance Notice of Proposed Rulemaking on Negative Option Marketing

On March 11, 2026, the Federal Trade Commission (FTC) issued a request for public comment on an advance notice of proposed rulemaking (ANPRM) regarding its “Rule Concerning the Use of Prenotification Negative Option Plans,” more commonly known as the “Negative Option Rule.” The FTC is inviting consumers and industry members to share their experiences with negative option marketing to help it decide whether and how …

Executive Order Seeks to Expand Access to Mortgage Credit

On March 13, 2026, the White House issued an executive order that directs the Consumer Financial Protection Bureau (CFPB) and federal housing and banking agencies to consider a series of mortgage-related regulatory and supervisory changes, with a particular focus on community banks (generally under $30 billion in assets) and “smaller banks” (under $100 billion in assets).  The order aims to “improve the availability and affordability …

OCC Proposes Rule Establishing Regulatory Framework for Issuing Stablecoins

The US Office of the Comptroller of the Currency (OCC) published its notice of proposed rulemaking (NPRM) to implement the provisions of the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act. Enacted in July 2025, the GENIUS Act establishes a national regulatory framework for payment stablecoin issuance and related activities in the United States. The proposed rulemaking would apply only to permitted payment …

New York Leads the Way on Buy Now, Pay Later Regulation

New York has taken a significant step toward comprehensive regulation of buy now, pay later (BNPL) by requiring licensure and disclosures designed for credit cards, even though BNPL transactions are closed end. The New York Department of Financial Services (NYDFS) recently published proposed rules to implement legislation that establishes a licensing and supervision framework for entities that provide BNPL services. The first-of-its-kind legislation, signed by Gov. …

HUD Proposes Rule Limiting Public Housing for Mixed Immigration Status Families

On February 20, 2026, the Department of Housing and Urban Development (HUD) published a proposed rule that would limit federal housing assistance for families with mixed immigration statuses. The proposed rule would revise HUD’s regulations implementing Section 214 of the Housing and Community Development Act of 1980 (Section 214), which limits financial assistance provided through HUD’s public housing programs to US citizens and certain categories …

US Treasury Releases New AI Risk Management Resources for Financial Institutions

The US Department of the Treasury recently announced two new resources to assist with the adoption of artificial intelligence (AI) in the financial services sector. The resources were developed by the Artificial Intelligence Executive Oversight Group (AIEOG), a public-private partnership between Treasury’s Financial and Banking Information Infrastructure Committee and the nonprofit Financial Services Sector Coordinating Council. They are part of a broader initiative to improve …

CFPB Adds Disclosures to Consumer Complaint Portal

The Consumer Financial Protection Bureau (CFPB) recently added two new disclosures and an attestation requirement to the CFPB portal through which consumers may submit complaints about a financial product or service. The recent additions are under the heading “Credit and consumer reporting complaint notice” and appear to be limited to complaints against consumer reporting agencies (CRAs) regarding inaccurate or incomplete information on a consumer report. …

FHFA Repeals Fair Housing and Fair Lending Rule

On February 6, 2026, the Federal Housing Finance Agency (FHFA) published a final rule repealing its Fair Lending, Fair Housing, and Equitable Housing Finance Plans regulation (part 1293).[1] Adopted in May 2024, part 1293 codified the FHFA’s fair housing and fair lending oversight of Fannie Mae, Freddie Mac and the Federal Home Loan Banks (together, the regulated entities). After publishing a notice of proposed rulemaking …

Navigating the Age Assurance Maze: FTC Signals Potential Guidance on Harmonizing COPPA With Robust Age Assurance Technologies

On January 28, the Federal Trade Commission (FTC) hosted a workshop on age assurance, where FTC leadership signaled new guidance may be forthcoming to clarify potential conflicts between age assurance efforts and federal law. At the workshop, titled, “Protecting American Children: A Workshop to Explore Age Verification Technologies,” FTC leadership acknowledged a tension between implementing age assurance technologies, which may be required to comply with …