The Conference of State Bank Supervisors (CSBS) recently issued interpretive guidance addressing the accounting treatment of stablecoins in the tangible net worth (TNW) calculation under its Model Money Transmission Modernization Act (MTMA). The guidance clarifies that CSBS intends for the definition of TNW under the MTMA to include, as “tangible financial assets,” stablecoins that meet certain criteria. The guidance is nonbinding, and it is uncertain …
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Part 2: NYDFS Sharpens Its Focus on Multifactor Authentication
Financial institutions covered by 23 NYCRR Part 500 (Part 500) (covered entities) must annually certify their compliance with these cybersecurity regulations. As the April 15 date for certifying compliance approaches, the New York Department of Financial Services (NYDFS) has been reinforcing its focus on one particular element of the updated requirements – multifactor authentication (MFA). On February 26, 2026, NYDFS hosted a public cybersecurity presentation …
FDIC Issues 2026 Consumer Compliance Supervisory Highlights
The FDIC recently published its annual Consumer Compliance Supervisory Highlights, covering examination results and consumer complaint trends for FDIC-supervised state-chartered banks and thrifts that are not members of the Federal Reserve System (supervised institutions). The report, summarized below, describes the FDIC’s findings from approximately 825 consumer compliance examinations of supervised institutions and from a review of approximately 32,000 consumer complaints. Most frequently cited violations identified …
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 …