|
Authorization for National Flood Insurance Program Expires
The National Flood Insurance Program’s (NFIP) authorization has been caught up in the federal government shut down fight, and the program’s authorization expired at 11:59 p.m. ET on September 30, 2025. As a result, FEMA will stop selling and renewing NFIP flood insurance policies until such time as the program is reauthorized. FEMA’s website notes that FEMA would still have the authority to ensure the payment of valid claims with available funds for existing policies.
G7 Cyber Expert Group Issues Statement on AI and Cybersecurity
In September 2025, the G7 Cyber Expert Group issued a statement regarding artificial intelligence (“AI”) and cybersecurity titled “Artificial Intelligence and Cybersecurity: Navigating Risk and Resilience in the Financial System”‘ (“the AI Statement”). The AI Statement intends to raise awareness of AI’s cybersecurity dimensions and outlines key considerations for financial institutions and regulatory authorities in the financial sector.
CFPB Finalizes Extended Compliance Dates for Section 1071
As previously reported by BCG, the Section 1071 Small Business Lending Data Collection (SBLDC) Rule (codified at 12 FR Part 1002, Subpart B) has survived various legal challenges from trade associations and lenders. However, in 2025 the SBLDC Rule came under fire again, this time from the CFPB itself, the agency that originally issued the rule. As discussed below, the compliance dates for the SBLDC Rule have once again been delayed.
NCUA Removes Use of Reputational Risk in Examinations
On September 25, 2025, the National Credit Union Administration (“NCUA”) issued a letter to credit unions (25-CU-05) announcing the elimination of reputation risk and equivalent concepts from its examination and supervisory processes. This action follows Executive Order (“EO”) 14331, titled “Guaranteeing Fair Banking for All Americans,” signed by the President in August 2025.
California Air Resources Board Issues New Guidance on California’s Climate Disclosure Regulations
California Senate Bill 261 (“SB 261”), enacted in 2023 and titled “Greenhouse Gases: Climate-related Financial Risk,” created a Climate-Related Financial Risk Disclosure Program for certain entities in California. SB 261 applies to companies with annual revenues exceeding $500 million that conduct business in California (“Covered Entities”). SB 261 requires Covered Entities to prepare a climate-related financial risk report disclosing the entity’s climate-related financial risk and the measures adopted to reduce and adapt to climate-related financial risk (“CRFR Report”).
Table of Contents
CONSUMER FINANCE
-
Authorization for National Flood Insurance Program Expires
-
Governor Signs LA Wildfire Mortgage Forbearance Into Law
-
New Law Amends FCRA to Ban Credit Reporting Agencies From Selling Mortgage “Trigger Leads”
-
Coalition of Trade Groups and Lenders File Lawsuit Challenging AB 130’s Subordinate Mortgage Servicing Provisions
BANKING OPERATIONS & FINTECH
-
G7 Cyber Expert Group Issues Statement on AI and Cybersecurity
-
FS-ISAC Recommends Adopting a Timeline to Implement Post Quantum Computing Defenses
-
Legislature Amends California’s Breach Notification Law
-
CPPA Finalizes Regulations on Cybersecurity Audits, Risk Assessments and ADMT
COMMERCIAL LENDING
-
CFPB Finalizes Extended Compliance Dates for Section 1071
-
SBA Releases Compliance Form to Assist Smaller Financial Institutions in Responding to SBA’s Debanking Letter
-
SBA Introduces New 7(a) Loan Program Aimed at Manufacturers
CREDIT UNIONS
-
NCUA Removes Use of Reputational Risk in Examinations
CORPORATE GOVERNANCE
-
California Air Resources Board Issues New Guidance on California’s Climate Disclosure Regulations
-
First Circuit Holds that Rhode Island Law Requiring Lenders to Pay Interest on Mortgage Escrow Accounts is Not Preempted by National Bank Act
-
Treasury Issues a Request for Comment on GENIUS Act Regulations
-
FinCEN Issues Guidance on Cross Border Information Sharing by Financial Institutions
-
FDIC Updates Enforcement Actions Manual Regarding Termination of Consent Orders
|
