Enforcement Actions

EO 14219 and MRAs, MRIAs & MRBAs -- an example from the FDIC Crypto Documents: EO 14219 orders agencies to de-prioritize (and terminate) enforcement inconsistent with Administration policy and legal views. The banking world saw a wave of terminations last week. But there will be others we can't see. That's because the EO's broad definition of "enforcement action" seems to encompass certain confidential supervisory processes that bank regulators do not typically deem "enforcement" -- including Matters Requiring Attention (MRAs), Matters Requiring Immediate Attention (MRIAs), and Matters...

On February 19, 2025, President Trump signed an Executive Order directing a broad-based effort to scale back administrative regulations and enforcement across the Federal Government (the “Deregulation Order”). The Deregulation Order calls for a government-wide review of regulations for modification or rescission under seven enumerated legal or policy grounds. It also orders agencies to de-prioritize enforcement inconsistent with Administration policy and legal views, including termination of ongoing proceedings. While the Deregulation Order applies to almost all domestic non-security...

On June 3, 2024, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) published its final rule creating a registry (“Registry”) of nonbank covered persons subject to certain agency and court orders (“Final Rule”). The Final Rule is effective on September 16, 2024, but the implementation dates vary based on type of entity (as discussed below). In short, under the Final Rule, nonbank covered persons subject to certain final public orders obtained or issued by a government agency in connection with the offering or provision of a consumer financial product or service must report the...