State and Local
Federal and State Efforts Intensify Focus on ‘Debanking’
In 2025, debanking initiatives continued to intensify, with new guidance, legislation, and other actions at both the federal and state levels aimed at so-called “discriminatory debanking.”…
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NYDFS Final Cybersecurity Rules – MFA, Asset Inventory, and Third-Party Risk
The last remaining provisions of the amendments to the New York Department of Financial Services’ (DFS) cybersecurity regulation called Part 500 came into effect Nov. 1, 2025.…
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Amended New York Transparency Act Broadens Entity Reporting Obligations Beyond Federal Standards
In the last week of the New York State legislative session, the Senate and Assembly passed S8432/A8662-A. As of Oct. 22, 2025, this legislation has not been sent to the governor for her signature.
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Florida Office of Financial Regulation Seeks to Amend and Expand Scope of De-Banking Rules
On Sept. 30, 2025, the OFR requested approval from the Florida Financial Services Commission to publish a Notice of Proposed Rule to amend Rules 69U-100.323 and 69U-100.3231 and for final…
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New York Enacts Landmark ‘Buy Now, Pay Later’ Regulation Amid Federal Regulatory Recalibration
As part of its FY 2026 budget, New York has enacted legislation to regulate Buy Now, Pay Later (BNPL) products and providers.
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California DFPI Issues Formal Rulemaking for Digital Financial Asset Regulation
The California Department of Financial Protection and Innovation (DFPI) on April 4, 2025, issued its formal notice of rulemaking for digital financial business regulation, following receipt of two sets of 2024 comments on its draft proposed rules for California’s “Digital Finance Assets Law” (DFAL) (AB 39 and SB 401, 2023).
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Effective April 14: FinCEN GTO Requires MSBs Along US Southwest Border to Report Transactions in Currency of More than $200
The Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring all money services businesses (MSBs) located in 30 ZIP codes across California and Texas to, among other things, report and maintain records of cash transactions exceeding $200 (up to $10,000), and to verify the identity of persons presenting such transactions…
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CFPB Guidance and State Consumer Protection: 2025 Considerations
To get ahead of potential staffing and priority changes under the new administration, on Jan. 14, 2025, the Consumer Financial Protection Bureau (CFPB) issued guidance to state attorneys general and…
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California DFPI Finalizes New Earned Wage Access Regulations
In October 2024, the California DFPI finalized regulations for providers of income-based advances (Earned Wage Access or EWA), clarifying registration requirements under the California Consumer Financial Protection Law (CCFPL). These…
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