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CFPB Issues New Supervision and Enforcement Priorities
In an April 16, 2025 memorandum circulated to CFPB employees, the CFPB’s Chief Legal Officer, Mark Paoletta, outlined the CFPB’s 2025 Supervision and Enforcement Priorities. The memo rescinds all prior enforcement and supervision priority documents.
Fifth Circuit Court of Appeals Dismisses CFPB UDAAP Examination Manual Suit
By way of background, in March 2022, the CFPB published an updated version of its UDAAP Examination Manual which included a provision stating that any act or practice that results in discrimination is an “unfair” practice, even if federal fair lending laws, such as the Equal Credit Opportunity Act, did not apply. As a result, the CFPB’s UDAAP authority was broadened to encompass discriminatory conduct in all consumer financial products and services, not just credit products.
More Changes Coming to the CFPB’s Small Business Lending Data Collection Rule
In early April 2025, the CFPB stated in a filing with the Fifth Circuit Court of Appeals in Texas Bankers Association, et al. v. CFPB (Case No. 24-4075) that it plans to reevaluate the regulation it issued for the Small Business Lending Data Collection (SBLDC) Rule (codified in 12 CFR Part 1002, Subpart B) and initiate a new rulemaking process.
NCUA Left with a Single Board Member
On April 16, 2025, President Trump fired the National Credit Union Administration’s (“NCUA’s”) two Democratic board members, Todd M. Harper (“Harper”) and Tanya F. Otsuka (“Otsuka”). The move controversially neutralizes the NCUA, which is left with just one Republican board member, Kyle Hauptman.
Further Changes in Guidance for Banks on Crypto-related Activities
As previously reported by BCG, several key agencies have issued clarifications and updates on permissible crypto-related activities for national banks and federal savings associations. Notably, on March 17, 2025, the OCC issued Interpretive Letter (“IL”) 1183, confirming that custodial services for crypto assets, specific stablecoin activities, and participation in independent node verification networks are acceptable for these institutions.
Table of Contents
CONSUMER FINANCE
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CFPB Issues New Supervision and Enforcement Priorities
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President Trump Issues Executive Order Instructing Federal Agencies to Cease Use of Disparate Impact Liability
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Credit Card Late Fee Rule Vacated by Federal Judge
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CFPB Will Not Defend Medical Debt Final Rule
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Regulators Issue Temporary Three-year Exception to Appraisal Requirements for Wildfire-impacted Los Angeles County
BANKING OPERATIONS & FINTECH
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Fifth Circuit Court of Appeals Dismisses CFPB UDAAP Examination Manual Suit
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FCC Delays Effective Date of TCPA Amendment
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New York Court Grants Citibank’s Motion to Appeal EFTA Ruling
COMMERCIAL LENDING
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More Changes Coming to the CFPB’s Small Business Lending Data Collection Rule
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Post-CECL Examination Takeaways
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SBA Issues New SOP 50 10 8 for 7(a) Loans
CREDIT UNIONS
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NCUA Left with a Single Board Member
CORPORATE GOVERNANCE
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Further Changes in Guidance for Banks on Crypto-related Activities
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SEC Ceases Defense of Climate Disclosure Rules
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OCC Announces Regulatory Priorities
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OCC Consolidates Divisions
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