Compliance

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CSBS Interpretive Guidance Clarifies Some Stablecoins May Be Included in Tangible Net Worth Calculations for Money Transmitters

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 …

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 …

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 …

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. …

Executive Order Seeks to Limit Large Institutional Investors From Purchasing Single-Family Homes

On January 20, 2026, the Trump administration issued an executive order to limit the purchase of single-family homes by Wall Street investors. Declaring it the administration’s policy that “large institutional investors should not buy single-family homes that could otherwise be purchased by families,” the executive order aims to “preserve the supply of single-family homes for American families and increase the paths to homeownership.” While the …

CFPB and DOJ Withdraw 2023 Statement on ECOA and Noncitizen Borrowers

On January 12, 2026, the Consumer Financial Protection Bureau (CFPB) and the Department of Justice (DOJ) formally withdrew their October 2023 joint statement addressing creditors’ consideration of immigration status under the Equal Credit Opportunity Act (ECOA) and its implementing Regulation B. The withdrawal is another explicit renunciation of the previous administration’s policies applicable to financial services, though the agencies were clear that withdrawal of the …

CFPB Submits to Court Order, Seeks New Funding

On January 9, 2026, the Consumer Financial Protection Bureau (CFPB) requested $145 million in new funding from the Federal Reserve. This development follows a ruling by the US District Court for the District of Columbia that the CFPB’s refusal to request additional funding from the Federal Reserve would violate the preliminary injunction in National Treasury Employees Union, et al. v. Russell Vought. The ruling, therefore, essentially required …