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 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 …
Key Fair Lending Updates From the Fed’s 2025 Interagency Webinar
On December 16, the Federal Reserve (Fed) hosted its annual Fair Lending Interagency Webinar, during which it, the National Credit Union Administration (NCUA) and the Consumer Financial Protection Bureau (CFPB) offered insight into their fair lending programs. The Fed highlighted its risk-focused approach to fair lending supervision, emphasizing the importance of tailored risk assessments, recurring training and robust monitoring of discretionary lending practices. Examiners continue …
OCC Releases Initial Findings From Debanking Review
The Office of the Comptroller of the Currency (OCC) recently shared initial findings from its ongoing review of potential debanking activities at the nine largest national banks it supervises. The review is part of the agency’s effort to implement mandates under Executive Order 14331, which directs “Federal banking regulators,” including the OCC, to remediate past instances, and prevent future acts of, politicized or unlawful debanking. The executive …
BNPL Market Remains Strong, Per CFPB Report
The Consumer Financial Protection Bureau (CFPB) released a data spotlight on the buy now, pay later (BNPL) market. Using data about the BNPL market for the years 2022 and 2023 from six large BNPL providers, the report describes trends and figures in BNPL market growth, borrower usage, late fees and charge‑offs. While there are different versions of the BNPL product, the report focuses on four-installment, …