INDUSTRY NEWS
OFAC EXTENDS RECORDKEEPING REQUIREMENTS TO 10 YEARS
Effective March 12, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) will require organizations to retain records of OFAC-related transactions for 10 years, doubling the previous 5-year requirement. The extended recordkeeping period applies to all transactions subject to OFAC regulations, including those involving blocked property or conducted under general or specific licenses. Organizations must adjust their compliance programs to meet the new retention period by the effective date to ensure adherence and mitigate potential penalties.
NEW YORK
NY BILL EXPANDS CONSUMER PROTECTION AUTHORITY
New York lawmakers introduced the FAIR Business Practices Act, which would give the state attorney general authority to prosecute “unfair” and “abusive” practices, expanding beyond the current focus on “deceptive” acts. The bill mirrors definitions under the Consumer Financial Protection Act and allows claims for even a single instance of misconduct, including harm to small businesses. Civil penalties would increase to $5,000 per violation, or up to $15,000 (or three times restitution) for willful violations. Additional penalties would apply if the harm involves vulnerable individuals, such as minors, seniors, veterans, or those with limited English proficiency. This legislation positions New York to fill enforcement gaps left by reduced federal oversight and strengthen consumer protections.
PENNSYLVANIA
PA ADVANCES CRYPTO LICENSING AND DATA PRIVACY BILLS
Pennsylvania is advancing several bills that signal increased regulatory oversight of financial and data-related activities. Senate Bill (SB) and House Bill 881 both aim to regulate virtual currency transmission under the state’s Money Transmitter Act, requiring companies that transmit crypto for a fee to obtain a license—while exempting self-hosted wallets. SB passed unanimously in the Senate, while HB 881 advanced through committee along party lines and may face amendments.
Additionally, HB 78, a bipartisan consumer data privacy bill, passed unanimously and would set rules for how companies collect, store, and sell consumer data online, though revisions are expected before a final vote.
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INDUSTRY NEWS
SENATE BILL WOULD LET FCC COLLECT TCPA FINES DIRECTLY
A new Senate bill would give the FCC the authority to collect fines for Telephone Consumer Protection Act (TCPA) violations without relying on the Department of Justice (DOJ). The FCC issues millions in fines for robocalls and telemarketing violations each year, but enforcement has been slow—only $6,790 of $200 million in fines were collected in 2019. The bill allows the FCC to take direct legal action if the DOJ doesn’t act within 120 days and prioritizes unpaid fines over $25 million. It also strengthens the FCC’s authority to issue rules protecting consumers from robocalls. The bill responds to rising public frustration with robocalls and could significantly ramp up enforcement.
INDUSTRY NEWS
SENATE ADVANCES BILL TO REGULATE PAYMENT STABLECOINS
The U.S. Senate Banking Committee has passed the GENIUS Act (Guiding and Establishing National Innovation for US Stablecoins Act), which would establish a comprehensive federal framework for issuing and regulating payment stablecoins. The bill would require stablecoin issuers to be licensed as one of three types: a federal qualified nonbank issuer (regulated by the OCC), a subsidiary of an insured depository institution (regulated by the Federal Reserve or FDIC), or a state qualified issuer (regulated by a state stablecoin regulator). Issuers would need to maintain 1:1 reserves backed by cash, Treasury securities, and other liquid assets, with regular public disclosures and audits. The act would preempt state money transmitter laws for federally regulated issuers and clarify that stablecoins are not securities or commodities under federal law. Non-U.S. issuers could face trading restrictions if they fail to comply with U.S. court orders. If passed, the bill would take effect 18 months after enactment or 120 days after final regulations are issued.
INDUSTRY NEWS
CFPB MARCH SNAPSHOT
March brought major developments for the Consumer Financial Protection Bureau (CFPB), as it faced both legal and legislative pressure over its structure and direction.
Judge Blocks Effort to Dismantle CFPB
A federal judge issued a preliminary injunction preventing the administration from shutting down the CFPB, citing violations of Congressional authority. The ruling comes after a wave of firings and cancellations of contracts critical to the Bureau’s function. The administration has appealed, leaving the agency’s long-term fate uncertain.
Congress Weighs CFPB Overhaul
On the legislative front, the House Financial Services Subcommittee is reviewing proposals to restructure the CFPB into a bipartisan commission and make it subject to annual appropriations. The TABS Act and the Consumer Financial Protection Commission Act are among the bills under consideration.
CFPB Pulls Back on Key Rules
In two significant moves, the CFPB signaled a retreat from recent rulemaking:
Buy Now, Pay Later (BNPL): The Bureau is working to revoke its 2024 interpretive rule applying credit card-like protections to BNPL products, following legal challenge by the Financial Technology Association. A joint court filing is seeking a pause in litigation as the rule is withdrawn.
Payday Lending Rule: The CFPB announced it will deprioritize enforcement of the Payment Withdrawal and Disclosure provisions of its small-dollar lending regulation, which took effect March 30. The agency said it is refocusing resources on more urgent consumer risks — particularly those affecting military families, veterans, and small businesses — and may issue new rulemaking to narrow the regulation’s scope.
CORPORATE TRANSPARENCY ACT
FINCEN EXEMPTS U.S. COMPANIES FROM BOI REPORTING, TIGHTENS FOREIGN RULES
On March 21, 2025, FinCEN issued an Interim Final Rule that immediately exempts all U.S.-formed companies from beneficial ownership reporting under the Corporate Transparency Act (CTA). These entities no longer need to file or update BOI reports.
Foreign entities registered to do business in the U.S. remain subject to BOI reporting and must file within 30 days of March 26 or their registration date. Only non-U.S. beneficial owners must be reported. The rule also limits reporting for foreign pooled investment vehicles to non-U.S. persons with control.
Public comments will be accepted, with a final rule expected later this year.
ALASKA
AK BILL EXPANDS LENDING LICENSING REQUIREMENTS
Alaska’s HB 132 expands lending licensing requirements and strengthens borrower protections for loans of $25,000 or less. The bill clarifies that a person or entity is subject to licensing if they hold the predominant economic interest in a loan, facilitate or service a loan with the option to purchase it, or structure loans to evade regulation. It caps interest rates on loans under $25,000 at 3% per month based on an actuarial method, including all fees and costs. The bill also prohibits lenders from threatening criminal prosecution for loan defaults and redefines “service charges” to exclude late fees and collection costs. Loans are considered to have occurred in Alaska if the borrower is a resident and completes the transaction while physically in the state, including online. If signed, the bill will take effect on July 1, 2025.
INDUSTRY NEWS
SENATE INTRODUCES BILL TO LIMIT “REPUTATIONAL RISK” IN FINANCIAL REGULATION
The U.S. Senate has introduced the Financial Integrity and Regulation Management Act (FIRM Act), which aims to prevent financial institutions from denying services to businesses based on subjective or politically motivated concerns, including “reputational risk.” The bill would require regulators like the OCC, Federal Reserve, and FDIC to focus on objective financial risks—such as credit and liquidity risk—rather than perceived reputational concerns. If passed, this could make it easier for crypto businesses to access banking services, reducing the practice of “de-banking” that has affected the sector. The bill would also prevent banks from terminating relationships with legal but controversial businesses, such as firearms or cryptocurrency firms, based on regulatory pressure. The FIRM Act is under review by the Senate Banking Committee, but its passage remains uncertain amid opposition from those who see reputational risk as a legitimate supervisory tool.
CAYMAN ISLANDS
CAYMAN ISLANDS INTRODUCES NEW CRYPTO LICENSING REQUIREMENTS
The Cayman Islands will implement new cryptocurrency licensing regulations starting April 1, 2025, requiring all virtual asset service providers (VASPs), including trading platforms and custody services, to obtain licenses from the Cayman Islands Monetary Authority (CIMA). Existing VASPs must submit license applications by June 29, 2025. The new rules mandate detailed disclosures, including the types and amounts of assets held, revenue expectations, cybersecurity measures, and internal controls to prevent theft and loss. The expanded oversight covers exchanges, asset transfers, custody services, and financial services related to virtual assets. While increased regulatory clarity may boost institutional investor confidence, the stringent requirements could raise operational costs and favor larger, well-established platforms. The new framework strengthens the Cayman Islands’ position as a major global hub for crypto businesses.
NORTH DAKOTA
ND BILL PASSED LIMITING CRYPTO ATM TRANSACTIONS
The North Dakota Senate has passed House Bill 1447, capping daily cryptocurrency ATM transactions at $2,000 to increase regulatory oversight and prevent fraud and money laundering. The bill passed with strong support (45–1) and is part of broader efforts to strengthen compliance with state and federal financial regulations. Crypto ATM operators may need to adjust their strategies as the cap could reduce transaction volumes and limit liquidity for businesses and investors. While supporters argue the limit will enhance consumer protection, critics warn it may deter crypto adoption and make the state less attractive to crypto businesses. The bill reflects a growing national trend toward stricter crypto regulations, aligning with SEC and FinCEN efforts to tighten compliance in the industry. If signed into law, it could serve as a model for other states considering similar restrictions.
CALIFORNIA
CA FINALIZES DEBT COLLECTION LICENSING REGULATIONS
The California Department of Financial Protection and Innovation (DFPI) has finalized regulations under the Debt Collection Licensing Act (DCLA), which take effect on July 1, 2025. The regulations clarify licensing and reporting requirements for debt collectors operating in California. Debt collectors must be licensed by the DFPI, submit annual reports, and pay a pro rata assessment based on net proceeds from California debtor accounts. The final rules define how to calculate net proceeds for debt buyers, debt owners, and third-party debt collectors. Licensees must also report the total number of debtor accounts collected, attempted but unpaid, and held at year-end.
BLOG POST
HOW REGULATORS ARE ADDRESSING DIGITAL PAYMENTS IN THE CRYPTO ERA
As cryptocurrencies reshape how we transfer value, regulators at both federal and state levels are working hard to establish guardrails for the industry. FinCEN, the SEC, and banking regulators are setting clearer rules around anti-money laundering (AML) programs, customer verification, and token classifications. At the state level, licensing requirements remain complex, with more than two dozen states adopting the Money Transmission Modernization Act (MTMA) to simplify oversight—though states like Texas, Vermont, and New York continue to set unique standards. With regulations tightening, crypto companies face mounting pressure to strengthen compliance—but those who adapt early can gain a competitive edge.
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INDUSTRY NEWS
FINCEN’S GTO NEW REPORTING REQUIREMENTS IMPACT MSBs
FinCEN has issued a Geographic Targeting Order (GTO) that directly impacts money services businesses (MSBs) in 30 ZIP codes across California and Texas. Starting 30 days after publication, MSBs must file Currency Transaction Reports (CTRs) for any cash transaction over $200—a significantly lower threshold than the usual $10,000. The GTO, lasting for 179 days, aims to disrupt money laundering tied to Mexico-based cartels and other criminal networks operating along the southwest border. MSBs will face increased compliance requirements and potential penalties for non-compliance. MSBs operating in the affected areas should prepare now to meet the enhanced reporting standards.
MASSACHUSETTS
MA PROPOSED NEW RULES ON JUNK FEES AND AUTO-RENEWALS
Massachusetts has introduced new consumer protection regulations targeting junk fees and misleading auto-renewal practices. Businesses are now required to disclose the total price of a product upfront, including mandatory charges, and ensure the total price is more prominent than other pricing details. The regulations also require clear disclosures on trial offers, including potential fees and cancellation deadlines. For auto-renewals, businesses must provide advance notice of renewal dates, charges, and cancellation options, and ensure that canceling is as easy as subscribing. If passed, businesses operating in Massachusetts must reassess their pricing and subscription practices to stay compliant before enforcement begins.
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NORTH CAROLINA
NC FINALIZES DEBT COLLECTION LICENSING REGULATIONS
North Carolina has introduced Senate Bill 491, known as the Debt Settlement Services Act. If enacted, this legislation would mandate that individuals or entities offering debt settlement services obtain a license from the Commissioner of Banks, with certain exemptions for banks, credit unions, and specific nonprofit organizations. Applicants must demonstrate financial responsibility and notify the Commissioner within 20 days if they cease operations. Additionally, acquiring more than a 25% ownership stake in a licensed entity would require prior approval from the Commissioner. Licensees would be obligated to submit annual reports detailing metrics such as the number and status of enrolled debts, total debt amounts managed, and settlement outcomes. Fee structures under the proposed act would allow charges up to 15% of the principal or 20% of the difference between the original debt amount and the settlement amount. The act also includes provisions against false advertising and outlines civil penalties up to $1,000 per violation, with enforcement authority granted to the Attorney General. If passed, the act would take effect on January 1, 2026.
OKLAHOMA
OK BILL TO SHIELD MEDICAL DEBT FROM CREDIT REPORTS
Oklahoma’s House Bill 1709 would prohibit creditors and debt collectors from reporting certain medical debt to credit bureaus. The bill specifically protects debt arising from lifesaving and emergency care services provided at an Oklahoma medical facility, such as hospitals, nursing facilities, and physician offices. Originally aimed at barring all medical debt from credit reports, the bill was amended to focus on emergency-related debt. If passed, the bill would take effect on November 1, 2025. Oklahoma has one of the highest rates of medical debt in the country, with nearly 20% of residents having medical bills in collections. The bill has passed the Civil Judiciary Committee and now awaits a Senate sponsor before moving forward.
NEW YORK
NY PROPOSED LICENSING RULES FOR BNPL LENDERS
New York has introduced the Buy Now Pay Later Act, which would require buy-now-pay-later (BNPL) lenders to obtain a license from the Superintendent of Financial Services to operate in the state. License applicants must meet financial solvency, capitalization, and credit access requirements, and licenses will remain valid unless revoked, suspended, or surrendered. The measure prohibits unlicensed BNPL loans, which would be considered void and uncollectable. Lenders must disclose loan terms, repayment schedules, and fees clearly to consumers, and are barred from charging interest, penalties, or late fees. Lenders must also maintain detailed business records for six years and file annual reports under penalty of perjury. If passed, the measure would take effect one year after enactment and introduce significant oversight of BNPL services in New York.
FLORIDA
FL BILL TARGETS DEFAULT INTEREST – NEW RETROACTIVE RULES COULD IMPACT LENDERS
Florida Senate Bill 392 proposes new compliance requirements for lenders, particularly impacting those involved in loan assignments and defaults. If enacted, the bill would prohibit lenders from collecting default interest unless a written notice of default is first issued to the borrower. Additionally, upon a loan sale or assignment, the original lender must provide a loan history report upon borrower request, and the new lender (assignee) must deliver a loan history and balance change statement within 30 days. One of the most significant aspects of the bill is its retroactive application to all existing loans, not just those originated after the July 1, 2025 effective date. The legislation is currently being reviewed by several Florida Senate committees and, if passed, would introduce new compliance and disclosure obligations for lenders and mortgage professionals operating in the state.
INDUSTRY NEWS
EWA LICENCING MOMENTUM GROWS ACROSS STATES
States are ramping up licensing and compliance requirements for earned wage access (EWA) providers. Arkansas and Utah have enacted laws, while Florida, Texas, and Ohio have active proposals in motion.
- Arkansas exempts compliant providers from lender and collector rules but mandates fee transparency, no-cost access, and bans on aggressive collections.
- Utah’s H.B. 279 requires non-employer EWA providers to register with the state by May 7, 2025.
- Florida (SB 422), Texas (HB 5462), and Ohio (HB 152) propose registration or licensing frameworks with consumer protections and operational standards. If passed, Florida and Texas would begin enforcement in 2026, and Ohio 91 days post-enrollment.
Across the board, states are aligning on core compliance themes: licensing, clear fee disclosures, no-cost access, tipping restrictions, and limits on repayment and credit reporting—marking a major regulatory shift for the EWA industry.
MINNESOTA
MN INTRODUCED BILL TO ALLOW BITCOIN FOR STATE INVESTMENTS AND PAYMENTS
Minnesota introduced the Minnesota Bitcoin Act, which would allow the state to use Bitcoin and other cryptocurrencies for retirement plans, state investments, and tax payments. The bill aims to modernize Minnesota’s financial infrastructure and provide new investment opportunities for residents. If passed, Minnesota would join Texas, New Hampshire, Colorado, and Utah in adopting similar legislation. The bill is positioned to encourage innovation and expand financial options for state residents.
INDUSTRY NEWS
LAWMAKERS MOVE TO OVERTURN CFPB MEDICAL DEBT RULE
Congressional resolutions have been introduced under the Congressional Review Act (CRA) to repeal the CFPB’s recent rule removing medical debt from consumer credit reports. Finalized in January 2025, its implementation was originally scheduled for March 17, but has been delayed until June 15 by a federal court order. If passed by Congress and signed by the President, the rule would be permanently voided. Lawmakers have until May 7 to act under the CRA’s fast-track procedures.
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UTAH
UT BITCOIN BILL PASSED WITH CUSTODY AND MINING PROTECTIONS
The Utah Senate has passed a Bitcoin bill that affirms the rights of residents to mine Bitcoin, operate nodes, and participate in staking while providing fundamental custody protections for Bitcoin holders. However, a provision that would have allowed the state treasurer to invest in Bitcoin was removed from the final version. The bill ensures that Utah residents can engage in Bitcoin-related activities without facing regulatory penalties. With the Senate’s approval, the bill now awaits Governor Spencer Cox’s signature to become law. If signed, Utah will join a growing list of states providing legal clarity and protections for cryptocurrency activities.
BLOG POST
WHAT MONEY TRANSMITTERS NEED TO KNOW ABOUT FINCEN’S NEW AML RULES
FinCEN’s new AML rules are raising the bar for MSBS, requiring a shift from checklist-based compliance to a more tailored, risk-based approach. MSBs must strengthen monitoring and reporting, especially if handling high-risk transactions or operating in regions prone to financial crimes. The new rules also emphasize transparency, requiring businesses to verify beneficial ownership and comply with the Travel Rule for crypto transactions. FinCEN’s recent $3.4 billion fine against Binance highlights the high stakes for non-compliance. With increased scrutiny on the horizon, now is the time to update your AML program, train your team, and invest in better technology.
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MARYLAND
MD LICENSING EXEMPTIONS PROPOSED FOR MORTGAGE AND LOAN ASSIGNEES
The Maryland Office of Financial Regulation (OFR) has proposed new legislation to address industry concerns over its January 2025 guidance requiring assignees of residential mortgage and installment loans to obtain a Maryland Mortgage Lender license by April 10, 2025. In response to market pushback, the OFR introduced the Maryland Secondary Market Stability Act, which would exempt assignees from licensing requirements if they do not engage in loan origination, brokering, funding, or servicing. The OFR also extended the enforcement deadline to July 6, 2025, to allow time for legislative changes. Business-purpose commercial loans are excluded from the licensing requirement, and Fannie Mae, Freddie Mac, and other federal entities are exempt. If enacted, the legislation would prevent passive trusts and certain assignees from needing a state license, reducing compliance burdens for secondary market participants.
WASHINGTON
WA BILL TO BAN MEDICAL DEBT FROM CREDIT REPORTS
The Washington State Senate has passed S. 5480, which would prohibit medical debt from being reported to credit reporting agencies. Violations would be classified as unfair or deceptive acts under the Washington Consumer Protection Act and improperly reported medical debt would be considered void and unenforceable. The bill now moves to the Washington House of Representatives for further consideration and potential approval.
ILLINOIS
IL PROPOSED MEDICAL DEBT COLLECTION RESTRICTIONS
Illinois has introduced Senate Bill 1223 to amend the Fair Patient Billing Act, adding new restrictions on medical debt collection practices. The bill would prevent medical creditors and debt collectors from pursuing collection actions while a patient’s health insurance appeal is pending or within 180 days after resolution. It also prohibits selling or transferring the debt to a collection agency during this period. If a patient qualifies for financial assistance, no interest can be added to the debt, and for those without assistance, interest is capped at 2% annually. The bill clarifies that forgiving co-pays or out-of-network charges would not violate patient-provider agreements.
This information is not intended to be, nor is it, legal advice. It is intended for information purposes only. We make no warranty, express or implied, as to the accuracy or reliability of this information. We are not attorneys. You must retain your own attorney to receive legal advice. While Cornerstone strives to provide the most current and accurate state licensing information, the responsibility for any decision related to state licensing or agency compliance is solely yours.
