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August

8
2025
Compliance

[PODCAST]: The Legality of Trump’s Terminations Without Cause of Members and Commissioners of Federal “Independent” Agencies

Today’s episode of the Consumer Finance Monitor podcast offers an in-depth analysis of the unitary executive theory and its implications for terminations by President Trump of the Democratic members/commissioners of several so-called independent Federal agencies.

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August

8
2025
Industry News

Comptroller Gould Issues Statement on Executive Order “Guaranteeing Fair Banking For All Americans”

Comptroller of the Currency Jonathan V. Gould today issued the following statement in support of the Executive Order, “Guaranteeing Fair Banking For All Americans,” issued by President Donald J. Trump:

Fair access to financial services is a fundamental principle of the U.S. banking system. It is unacceptable for banks to discriminate against any customer on the basis of political or religious beliefs or lawful business activities. Today’s Executive Order affirms that banks should provide access to financial services based on individualized, objective, and risk-based analyses.
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August

7
2025
Compliance

Everything You Need to Know About the California Consumer Privacy Act (CCPA) in 2025

On July 1, 2025, the California Attorney General settled with Healthline for $1.55 million, the highest CCPA-related fine to date, citing failure to limit data purpose and lack of sufficient disclosures under the purpose-limitation principle.

Imagine having complete insight and control over how your personal information is collected, shared, and sold. That’s what the California Consumer Privacy Act (CCPA) brought in 2020. Then came the California Privacy Rights Act (CPRA), effective January 2023, expanding those rights and establishing the California Privacy Protection Agency (CPPA) to enforce them. These laws together position California at the forefront of privacy regulation in the United States.

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August

7
2025
Compliance

FDIC clarifies that CIP Rule does not preclude using pre-populated customer information

On August 5, 2025, the Federal Deposit Insurance Corporation (FDIC) issued FIL-39-2025 to state that an FDIC-supervised institution can use pre-populated customer information to satisfy the requirements of the Customer Identification Program Rule, implementing part of the USA PATRIOT Act (CIP rule).

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August

7
2025
Compliance

Regulatory Requirements Related to Adverse Action Notifications

As part of the Federal Reserve Board’s Outlook Live Webinar series, on July 17, 2025, examiners from the Minneapolis and Chicago Federal Reserve Banks hosted a webinar to discuss the regulatory requirements related to adverse action notifications under the Equal Credit Opportunity Act (ECOA), as implemented by Regulation B, and the Fair Credit Reporting Act (FCRA). We thought the information that was presented would be helpful to our clients and friends who are just getting acquainted with these issues and would be a good refresher for our clients and friends who are longtime practitioners in consumer financial services law.

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