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CFPB Withdraws Multiple Guidance Documents and Rules
On May 12, 2025, the CFPB announced the withdrawal of 67 regulatory guidance documents, including interpretive rules, policy statements, and advisory opinions. 90 FR 20084. The withdrawals are applicable as of May 12, 2025. Shortly after the guidance withdrawal, the CFPB pulled back a proposed rule, interim final rule, and interpretative rule.
OFAC Recordkeeping Final Rule Now in Effect
On September 13, 2024, the Office of Foreign Assets Control (OFAC) published an interim final rule amending its regulations to extend the recordkeeping requirement for transactions subject to OFAC sanctions programs from five years to 10 years. This change is intended by OFAC to ensure records are maintained consistent with a new statute of limitations for violations of certain sanctions prohibitions administered by OFAC, which went into effect on April 24, 2024.
CFPB Asks Court to Halt Compliance Dates for Section 1071 Rule
As previously reported by BCG, the Section 1071 Small Business Lending Data Collection (SBLDC) Rule (codified in 12 FR Part 1002, Subpart B) has survived various legal challenges by trade associations and lenders. However, the SBLDC Rule came under fire again in 2025, this time from the CFPB itself (the agency that originally issued the rule).
OCC Issues New Interpretive Letter on Crypto-asset Services
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. For instance, 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. IL 1183 also confirmed the OCC’s position on various crypto-related activities addressed in prior ILs, including whether banks may provide custodial services for crypto assets in IL 1170.
Table of Contents
CONSUMER FINANCE
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CFPB Withdraws Multiple Guidance Documents and Rules
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Trump Signs CRA Nullifying Overdraft Lending Rule
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HUD Updates SCRA Notice
BANKING OPERATIONS & FINTECH
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OFAC Recordkeeping Final Rule Now in Effect
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Changes to Small Estate Affidavit Amounts and Impact of AB 2016
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Changes to Levy Exemption Amounts
COMMERCIAL LENDING
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CFPB Asks Court to Halt Compliance Dates for Section 1071 Rule
CREDIT UNIONS
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NCUA Left with a Single Board Member
CORPORATE GOVERNANCE
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OCC Issues New Interpretive Letter on Crypto-asset Services
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OCC Rescinds 2024 Merger Guidance
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Agencies Issue Updated Host State Loan-to-Deposit Ratios
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