All in Regulatory Update

On March 26, 2025, the CFPB announced that it is seeking to vacate the settlement the CFPB extracted from Townstone back in 2024 after suing the nonbank retail-mortgage creditor for discriminatory lending practices and redlining. In its press release, the CFPB stated that after a thorough review, the Bureau is seeking to “make Townstone whole by returning the six-figure penalty they were forced to pay.”

On March 24, 2025, FinCEN issued a set of Frequently Asked Questions for the Geographic Targeting Order involving certain money services businesses in California and Texas on the Southwest Border. This is in relation to the March 11 GTO requiring all money services businesses located in 30 ZIP Codes across California and Texas to file additional Currency Transaction Reports (CTRs) with FinCEN for transactions above $200 but not more than $10,000.

On March 11, 2025, FinCEN issued a notice of a Geographic Targeting Order requiring certain money services businesses along the southwest border of the United States to report and retain records of transactions in currency of more than $200 but not more than $10,000, and to verify the identity of persons presenting such transactions. The order will take effect starting April 14, 2025 and ends on September 9, 2025.

On March 7, 2025, the OCC issued a letter to reaffirm that a range of cryptocurrency activities are permissible in the federal banking system. Through Interpretive Letter 1183, the OCC confirmed that crypto-asset custody, certain stablecoin activities, and participation in independent node verification networks such as distributed ledger are permissible for national banks and federal savings associations.

On 3/3/25, the FDIC announced that it was postponing the compliance date from May 1, 2025 to March 1, 2026 for the requirements under 12 CFR 328.5 related to the display of the FDIC official digital sign on an insured depository institution’s (IDI’s) digital channels, as well as analogous requirements related to IDI’s automated teller machines (ATMs) and like devices under 12 CFR 328.4.

On 3/3/25, the FDIC announced that it was withdrawing three proposed rules relating to brokered deposits, corporate governance, and the Change in Bank Control Act (CBCA). The FDIC also announced a withdraw of the authority previously approved by the FDIC Board of Directors to publish a proposed rule on incentive-based compensation arrangements.