The Roundup: NY to Toughen Laws, OCC Ceases Exams for Reputation Risk, and a $17M Deceptive Ad Enforcement Action
Welcome to the PerformLine Regulatory Compliance Roundup, home of the latest news, articles, and reports from our industry, curated for you. Let’s get into it.
In this edition: New York to toughen up laws to make up for weakened CFPB, OCC ceases examinations for reputation risk, U.S. Treasury Department prepares to streamline banking regulators, the future of UDAAP looks to the states, U.S. regulation survey 2025: compliance at a crossroads, and bridging the creativity and compliance gap with Ryan Bowling at OMB Bank.
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New York to Toughen Up Laws to Make Up for Weakened CFPB
New York is advancing the FAIR Business Practices Act, a major overhaul of its outdated consumer protection laws, aiming to combat deceptive and abusive business tactics amid weakened federal oversight. Championed by Attorney General Letitia James, the bill expands protections against predatory lending, hidden fees, misleading subscription policies, and unfair debt collection while boosting enforcement powers and penalties.
It targets practices harming vulnerable populations, including seniors and non-English speakers, and mandates transparency in online and financial transactions. With broad support from state leaders and consumer advocates, the legislation seeks to modernize safeguards and hold businesses accountable for unethical conduct.
OCC Ceases Examinations for Reputation Risk
The Office of the Comptroller of the Currency (OCC) announced it will no longer assess banks for reputation risk, removing related references from its handbooks and guidance. This move aligns with the OCC’s focus on transparent, objective supervision by emphasizing concrete risk management and legal compliance rather than public perception. Acting Comptroller Rodney E. Hood clarified that the OCC has never used reputation risk to justify supervisory actions or influence bank business decisions. While ending formal reputation risk evaluations, the OCC will continue to expect banks to uphold strong risk management practices across all other areas.
Significant Stat: $17 Million: An online cash advance company has agreed to pay $17M to the FTC for deceiving consumers about how much money they could get and how fast that money could be made available. Read more
U.S. Treasury Department Prepares to Streamline Banking Regulators
The U.S. Treasury Department is preparing recommendations to streamline banking regulators, potentially affecting the OCC and the Federal Deposit Insurance Corporation (FDIC). Aimed at strengthening Treasury’s oversight of major banks, the move aligns with the Trump administration’s broader strategy to expand presidential power and exert greater control over independent agencies. This follows recent actions including regulator staff cuts, defunding programs, and weakening consumer protections, signaling a continued push to reshape the financial regulatory landscape and reduce oversight.
The Future of UDAAP: Look to the States?
As federal enforcement of Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) is in a holding pattern at the CFPB, attention is shifting to state-level initiatives to protect consumers. States like California and New York are leading efforts to expand UDAAP laws, targeting practices such as overdraft fees and predatory lending. Financial institutions must monitor these state developments and maintain robust compliance policies to navigate the evolving regulatory landscape effectively.
U.S. Regulation Survey 2025: Compliance at a Crossroads
The 2025 US Regulation Survey reveals that financial institutions are navigating a challenging regulatory environment marked by shifting federal and state policies, mounting uncertainty, and evolving compliance demands. Conducted as the Trump administration resumed power and began reorienting key regulations, the survey captured the perspectives of 200 organizations grappling with tight deadlines, rising costs, and the need for technological adaptation. Key findings highlight the industry’s focus on regulatory impact, operational adjustments, and the increasing role of automation and partnerships in streamlining compliance and modernizing frameworks.
Bridging the Creativity and Compliance Gap at OMB Bank
In a recent COMPLY Podcast episode, Ryan Bowling, VP and Director of Marketing at OMB Bank, discusses how creativity and compliance can work hand-in-hand to create impactful, regulation-friendly marketing. Drawing from his journalism roots and banking experience, Bowling shares strategies for integrating compliance early in campaign planning to avoid delays, emphasizes the importance of cross-team education to build trust, and highlights tools like PerformLine that automate compliance checks. He also showcases how OMB Bank keeps marketing fresh and engaging—even in a regulated industry—with standout initiatives like their quirky pickleball campaign.
