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On March 11, 2026, the Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (“CFTC”) announced that they have entered into a new Memorandum of Understanding (“MOU”) to coordinate rulemaking, supervision, examinations and enforcement across areas where the agencies’ jurisdiction overlaps.
On February 25, 2026, the Office of the Comptroller of the Currency (the “OCC”) issued a Notice of Proposed Rulemaking (the “NPRM”) to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”). The proposal would add a new Part 15 to the OCC’s regulations and establish the supervisory framework applicable to “permitted payment stablecoin issuers” subject to OCC jurisdiction. The comment period will run for sixty days after publication in the Federal Register.
On January 28, 2026, the SEC’s Divisions of Corporation Finance, Investment Management, and Trading and Markets issued a joint statement addressing “tokenized securities.” The staff defines a tokenized security as a financial instrument that already fits within the statutory definition of a “security,” but is “formatted as or represented by a crypto asset,” with ownership recorded in whole or in part on a crypto network. In other words, putting a security “onchain” does not in and of itself change the security into something else.
In the recently grand tradition of Maryland making waves in the consumer financial services space, the Mayor and City Council of Baltimore filed suit against Dave, Inc., a fintech that uses a “proprietary AI underwriting model that analyzes cash flow, not credit scores” to offer a product called “ExtraCash” to consumers when it looks like their budget might be tight.
In a February 3, 2026 speech to the Investment Company Institute’s Winter Board Meeting, Brian Daly, Director of the SEC’s Division of Investment Management, requested industry comment on how the use of artificial intelligence solutions should be addressed by the federal securities laws and processes.
On December 19, 2025, the Federal Reserve Board issued a Request for Information (“RFI”) on a proposed “Payment Account prototype.” The proposal responds to growing pressure from payments-focused institutions — particularly uninsured and novel charter entities — seeking faster, more predictable access to Federal Reserve payment rails that currently are only available with a Federal Reserve Bank master account.
The Consumer Financial Protection Bureau (CFPB) will receive a new infusion of funding which was announced by the CFPB’s Acting Director, Russell Vought, who is also the Director for the Office of Management and Budget. The request for funding was required by the District of the District of Columbia judge overseeing the lawsuit brought by the CFPB’s worker’s union, the National Treasury Employees Union. Accordingly, Vought has requested $145 Million to fund the CFPB at least through March of this year.
On December 22, 2025, the Board of Governors of the Federal Reserve (the Board) issued a final rule that rescinded a 2023 policy statement and that in turn issued a new policy statement. In a memo submitted to the Board in November, Board staff explained that the 2023 policy statement was put into place at the time to address “particular sets of facts related to certain crypto-assets” and that the policy was intended to describe how the Board would approach regulating state member banks interested in engaging in such crypto-asset activities.
The Consumer Financial Protection Bureau released its updated dollar amounts for the threshold at which consumer loans are not covered by much of the consumer protections available pursuant to the Truth In Lending Act (TILA) and the Consumer Leasing Act (CLA). For 2026, the exemption threshold increases to $73,400 from $71,900 in 2025.
On December 16, 2025, the FDIC issued a notice of proposed rulemaking to implement the application and approval requirements under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”) for insured state nonmember banks and state savings associations seeking to issue payment stablecoins through a subsidiary. The proposal would add a new § 303.252 to the FDIC’s filing procedures in 12 C.F.R. Part 303, establishing a tailored, statute-driven process for obtaining FDIC approval to form and operate a “permitted payment stablecoin issuer” (“PPSI”) subsidiary.