Regulatory Updates
Updates the regulatory team is monitoring across the verticals we file in. Effective dates, severity, and impact in one feed.
A new penalty schedule for debt collectors became effective in NYC on September 1, 2026, but the substantive SHIELD Rule has been delayed to January 1, 2027.
The Massachusetts Attorney General filed a proposed consent judgment to permanently bar a debt buyer/operator from collection activities due to several alleged violations.
The OCC, alongside other agencies, is requesting comments on proposed third-party risk management guidance intended to tailor risk management practices to the specific risk profiles of third-party relationships.
The OCC issued an interim final rule that expands eligibility for the 18-month on-site examination cycle from institutions under $3 billion in assets to those under $6 billion, provided they meet certain criteria.
The Texas SML issued a stakeholder notice regarding conceptual rule changes on August 27, 2026.
On August 2026, the FTC announced it stopped a large credit-repair scheme that used deceptive marketing tactics.
The Texas Department of Banking issued a Consent Order against Lockeson Escrow, Inc. d/b/a GunTab on September 1, 2026, for unlicensed money transmission.
The OCC issued an interim final rule on September 10, 2026, expanding eligibility for longer examination cycles for certain institutions.
The OCC issued joint FAQs on September 8, 2026, regarding the use of state-issued mobile driver's licenses and digital verifiable credentials under the Customer Identification Program rule.
On September 2, 2026, the OCC released a joint statement clarifying SAR confidentiality requirements. This is particularly relevant for banks when communicating with customers about suspicious activities.
The OCC announced the Fourth Quarter 2026 and First Quarter 2027 CRA Evaluation Schedule on August 31, 2026. This update impacts the examination timing and supervisory expectations for covered institutions.
Enforcement under the California Debt Collection Licensing Act continues with specified compliance requirements for licensed debt collectors.
The OCC proposed a rule to refine the issuance of MRAs by distinguishing between substantive violations, which have meaningful impacts, and technical violations, which do not warrant an MRA.
The OCC released revised internal manuals for bank enforcement actions emphasizing escalation, tailoring, and focus. The revisions stress that supervisory observations do not automatically create remediation expectations.
A notice of proposed rulemaking was issued by the OCC on August 27, 2026, categorizing violations into 'substantive' and 'technical. ' This aims to focus supervisory attention on impactful violations.
The OCC revised its internal Policies and Procedures Manuals on August 27, 2026, emphasizing three principles for enforcement decisions: escalation, tailoring, and focusing corrective actions on deficiencies.
On August 27, 2026, the OCC and FDIC issued a joint final rule defining 'unsafe or unsound practice' for enforcement purposes. The intent is to clarify supervision and focus on material financial risks.
FTC sets the FY 2027 National Do Not Call Registry access fees for telemarketers, effective October 1, 2026.
A notice of proposed rulemaking to refine conditions under which a Matter Requiring Attention can be issued based on violations of laws.
CSBS reported on the enactment of the Money Transmission Modernization Act in 31 states, which streamlines money transmitter licensing.
FinCEN reissued a Geographic Targeting Order that mandates enhanced reporting for cash transactions at MSBs along the southwest border.
FinCEN issued an alert about the rise of digital asset investment scams and urged financial institutions to enhance monitoring.
The OCC published its CRA evaluation schedule for the next two quarters, providing banks with essential planning information.
The OCC proposed a rule categorizing substantive and technical violations in relation to MRAs for banks.
The effective date of NYC's SHIELD Rule, initially set for September 1, 2026, has been postponed to January 1, 2027.
Connecticut's Department of Banking took enforcement action against CDS Debt Relief LLC on August 21, 2026, for unlicensed debt negotiation practices.
Texas announced a licensing fee schedule effective September 1, 2026.
A joint statement regarding SAR confidentiality was issued on September 2, 2026 by FinCEN and other agencies.
The OCC issued Bulletin 2026-39 on August 25, 2026, rescinding the interagency statement on special purpose credit programs.
During the period from August 23 to September 6, 2026, no new CFPB enforcement actions or rules were issued.
The CSBS updated its tracking of the Money Transmission Modernization Act, indicating 31 states have enacted the law partially or entirely as of August 2026.
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