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Articles by Kristen Larson
CFPB Restores CSI Treatment Of "Pose Risk" Decisions
Kristen Larson’s articles from Ballard Spahr LLP are most popular: within Finance and Banking topic(s) in United States Ballard Spahr LLP are most popular: within Finance and Banking, Cannabis & Hemp and Antitrust/Competition Law topic(s) Effective October 27, 2025, the CFPB rescinded the amendments to the Procedures for Supervisory Designation Proceedings that it adopted in April 2022, November 2022, and April 2024, , with the exception of some limited process adjustments.
CFPB Withdraws Proposed Registry Of Nonbank Contract Terms
Kristen Larson’s articles from Ballard Spahr LLP are most popular: within Finance and Banking topic(s) in United States Ballard Spahr LLP are most popular: within Finance and Banking, Cannabis & Hemp and Antitrust/Competition Law topic(s) On October 29, 2025, CFPB withdrew its proposed rule titled Registry of Supervised Nonbanks That Use Form Contracts To Impose Terms and Conditions That Seek To Waive or Limit Consumer Legal Protections, which was published on February 1, 2023.
CFPB rescinds amendments to the Rules of Practice for Adjudication Proceedings
Effective October 29, 2025, the CFPB finalized its rule, published at 90 Fed. Reg. 48737-60, rescinding certain amendments to the rules made on February 22, 2022 (prior blog) and on March 29, 2023 (prior blog) (collectively, the 2022 and 2023 amendments). Under Section 1053(e) of the Consumer Financial Protection Act, the CFPB is authorized to prescribe rules for hearings and adjudication proceedings. Those rules are codified at 12 C.F.R. Part 1081.
Judge Delays Effective Dates Of CFPB's Open Banking Rule
Kristen Larson’s articles from Ballard Spahr LLP are most popular: within Finance and Banking topic(s) in United States Ballard Spahr LLP are most popular: within Finance and Banking, Cannabis & Hemp and Antitrust/Competition Law topic(s) A federal judge has issued an injunction delaying the compliance dates of the CFPB's open banking rule ("Rule"). In issuing the injunction, U.S. District Judge Danny C.
Third Circuit Affirms Rule 11 Sanctions, Thwarting Law Firm’s Use of Spurious Dispute Letters to Tee up FDCPA Claims
In a recent published opinion, the Third Circuit affirmed the District Court’s sanctions against JP Ward & Associates, attorney Travis Gordon, and attorney Joshua Ward for engaging in, as the District Court put it, “a campaign of deception.”.
NY Attorney General Sues Early Warning Services For Zelle Network's Lax Security Measures
Last month, New York Attorney General Letitia James sued Early Warning Services, LLC (EWS), the company that operates the Zelle Network, for allegedly failing to protect its users from fraud.
NY Attorney General sues Early Warning Services for Zelle Network’s lax security measures
Last month, New York Attorney General Letitia James sued Early Warning Services, LLC (EWS), the company that operates the Zelle Network, for allegedly failing to protect its users from fraud.
Third Circuit Affirms Rule 11 Sanctions, Thwarting Law Firm's Use Of Spurious Dispute Letters To Tee Up FDCPA Claims
In a recent published opinion, the Third Circuit affirmed the District Court's sanctions against JP Ward & Associates, attorney Travis Gordon, and attorney Joshua Ward for engaging in, as the District Court put it, "a campaign of deception.".
CFPB Spring 2025 Regulatory Agenda - Final Rule Stage - Remittance Transfer Rule (Regulation E)
The CFPB announced in its Spring 2025 Regulatory Agenda that it will be finalizing amendments to the Remittance Transfer Rule under Regulation E, which implements the Electronic Funds Transfer Act (EFTA), to revise disclosure requirements and corresponding model forms to include clarifying information about the types of inquiries that may be most efficient to direct to the CFPB and the State agency that licenses the remittance transfer provider.
CFPB Spring 2025 Regulatory Agenda - Final Rule Stage - Remittance Transfer Rule (Regulation E)
The CFPB announced in its Spring 2025 Regulatory Agenda that it will be finalizing amendments to the Remittance Transfer Rule under Regulation E, which implements the Electronic Funds Transfer Act (EFTA), to revise disclosure requirements and corresponding model forms to include clarifying information about the types of inquiries that may be most efficient to direct to the CFPB and the State agency that licenses the remittance transfer provider.
Third Circuit affirms Rule 11 sanctions, thwarting law firm’s use of spurious dispute letters to tee up FDCPA claims
In a recent published opinion, the Third Circuit affirmed the District Court’s sanctions against JP Ward & Associates, attorney Travis Gordon, and attorney Joshua Ward for engaging in, as the District Court put it, “a campaign of deception.”.
CFPB Spring 2025 Regulatory Agenda - Prerule Stage - Identity Theft And Coerced Debt (Regulation V)
BS Ballard Spahr LLP More Ballard Spahr LLP—an Am Law 100 law firm with more than 750 lawyers in 18 U.S. offices—serves clients across industries in litigation, transactions, and regulatory compliance. A strategic legal partner to clients, Ballard goes beyond to deliver actionable, forward-thinking counsel and advocacy powered by deep industry experience and an understanding of each client’s specific business goals.
New Consumer Financial Services Fintech Business Opportunities Arising From Deregulation At The CFPB During Trump 2.0 - Part 1 (Podcast)
In the latest episode of our podcast, we explore the significant shifts in the regulatory landscape under the second Trump administration and how these recent deregulatory actions have opened new pathways for banks and FinTech companies by reducing barriers to entry and compliance costs. This evolving environment presents opportunities for innovation and market expansion, although state law oversight, including licensing and regulatory requirements.
CFPB Invites Comments On New Section 1033 'Open Banking' Rule
As promised, the CFPB is issuing an Advance Notice of Proposed Rulemaking soliciting comments on the agency's open banking rule. In the notice, scheduled to be published in the Federal Register on August 22, 2025, the CFPB lists four areas it wants addressed and then provides a list of questions that commenters might answer. Those four areas are: The proper understanding of who may serve as a "representative" of the consumer.
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).
U.S. Senate Introduces Act To Apply AML/BSA Laws To Art Dealers And Auction Houses
On July 23, 2025, Senators John Fetterman (D-PA), Chuck Grassley (R-IA), Sheldon Whitehouse (D-RI), Bill Cassidy (R-LA), Andy Kim (D-NJ), and David McCormick (R-PA), introduced the federal Art Market Integrity Act (the "Act"). The Act is bipartisan legislation that would require art dealers and auction houses to comply with anti-money-laundering and counter-terrorism financing regulations under the Bank Secrecy Act ("BSA").
FTC Takes Action Against Accelerated Debt For Running A Debt Relief Scam
An ex parte temporary restraining order has been issued against the participants in a debt relief services scheme that allegedly targeted seniors, including veterans, using a variety of deceptive practices, including falsely impersonating consumers' banks and credit card companies. Susan M Brnovich of the U.S. District Court for the District of Arizona issued the restraining order at the request of the Federal Trade Commission ("FTC").
Eighth Circuit Voids FTC 'Click To Cancel' Rule
A federal appeals court has nullified the Federal Trade Commission's amendments to its Negative Option Rule intended to make it easier for people to cancel subscriptions. Custom Communications, the U.S. Chamber of Commerce, and other groups filed suit challenging the amendments to the rule, contending that the FTC did not follow proper procedures in enacting them.
Eighth Circuit voids FTC ‘Click to Cancel’ rule
A federal appeals court has nullified the Federal Trade Commission’s amendments to its Negative Option Rule intended to make it easier for people to cancel subscriptions. Custom Communications, the U.S. Chamber of Commerce, and other groups filed suit challenging the amendments to the rule, contending that the FTC did not follow proper procedures in enacting them.
Federal Judge vacates CFPB medical debt rule
A Texas federal judge has voided a Biden Administration CFPB rule that would have prohibited medical debt in credit reports. “The Bureau has no such power to define what in a consumer report is ‘permissible,’” Judge Sean D. Jordan of the Eastern District of Texas wrote.
Federal Banking Agencies Seek Information On Actions To Address Payments Fraud
BS Ballard Spahr LLP More Ballard Spahr LLP—an Am Law 100 law firm with more than 750 lawyers in 18 U.S. offices—serves clients across industries in litigation, transactions, and regulatory compliance. A strategic legal partner to clients, Ballard goes beyond to deliver actionable, forward-thinking counsel and advocacy powered by deep industry experience and an understanding of each client’s specific business goals.
Federal banking agencies seek information on actions to address payments fraud
On June 20, 2025, the Office of the Comptroller of the Currency (OCC), Treasury, the Board of Governors of the Federal Reserve System (FRB), and the Federal Deposit Insurance Corporation (FDIC) announced they are seeking public input on questions related to payments fraud.
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