MVA White Collar Defense, Investigations, and Regulatory Advice Blog

North Carolina has joined a growing number of states seeking to address the consumer-protection risks associated with cryptocurrency kiosks. On July 8, 2026, Governor Josh Stein signed House Bill 920 into law, creating the Virtual Currency Kiosk Consumer Protection Act (the “Act”), which provides a comprehensive regulatory framework governing virtual currency kiosks operating in the State. The Act takes effect on January 1, 2027.

The Act is similar to model legislation used by many other states that are seeking to balance consumer demand for access to transactions in ...

MVA attorneys Kate Wellman, John Stoker and Neil Bloomfield co-author the Law360 article titled, “FDIC Proposals Mark Pullback In Bank Resolution Rules” which was published on July 23.

The Federal Reserve Board and FDIC’s (the Agencies) May 2026 feedback to the eight U.S. Global Systemically Important Banks (GSIBs) signals a potential meaningful shift in resolution planning supervision. While the Agencies reaffirmed their focus on operational capabilities developed through prior feedback letters, they stopped short of directing firms on how to further refine them. Instead, they placed responsibility on the GSIBs to critically examine their own capabilities and adapt them to changes in market conditions and each institution’s specific activities and ...

On May 5, 2026, a majority panel of the U.S. Court of Appeals for the Second Circuit (the “Second Circuit”) issued an opinion holding that the National Bank Act (NBA) preempts New York General Obligations Law (GOL) § 5‑601, which requires banks to pay interest on mortgage escrow accounts. Cantero v. Bank of America, N.A., __F.4th __, 2026 U.S. App. LEXIS 13066 (2d Cir. May 5, 2026) (“Cantero III”). The decision marks the second time the Second Circuit has concluded that GOL § 5‑601 is preempted by the NBA, having previously done so in 2022. Cantero v. Bank of America, N.A., 49 ...

On May 1, 2026, the Consumer Financial Protection Bureau (CFPB) released its long-anticipated final rule (the “Final Rule”) revising its initial rulemaking in 2023 (the “Prior Rule”) to implement the small business lending data collection requirements under Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The Prior Rule was the subject of extensive litigation, re-proposals and compliance date extensions, which the CFPB, in the Final Rules, attributes to the Prior Rule’s expansive collection requirements. The Final Rule has a compliance date of January 2028, and the revisions will result in a reduction in both the number of institutions subject to its requirements and the number of data points, and detail, required to be collected. In addition, the Final Rule removes references in the Prior Rule to presumptive indicia that an institution may have discouraged applicants from providing requested data. Below, we set out key areas where the Final Rule revised prior requirements.

Early 2026 developments from the Farm Credit Administration (FCA) show the regulator is identifying opportunities to reduce regulatory complexity while reinforcing risk management expectations across Farm Credit System (FCS or System) institutions.

As with the federal banking agencies, the FCA opened the year with a proposed capital reform measure. But FCA Board Chairman and CEO Jeffrey Hall indicated that the agency does not anticipate broader structural changes to capital requirements. The FCA also issued new guidance clarifying expectations for policies, procedures ...

On April 24, 2026, the Office of the Comptroller of the Currency (OCC) issued two coordinated interim final actions:

• an Interim Final Rule amending 12 CFR § 7.4002 governing national bank non‑interest charges and fees (the “Interim Final Rule”)[1], and
• an Interim Final Order preempting Illinois’s Interchange Fee Prohibition Act (IFPA) under the National Bank Act (NBA) and Home Owners’ Loan Act (HOLA) (the “Interim Final Order”).

Together, these actions are intended to reaffirm the authority of national banks under federal law to earn and receive interchange fees and to prevent the imminent application of Illinois’s first‑of‑its‑kind state interchange fee restrictions to OCC‑regulated institutions. Both actions are effective June 30, 2026, and both are subject to a post‑issuance comment period.

In March 2026, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (the “Federal Reserve”), and the Federal Deposit Insurance Corporation (FDIC, and together with the OCC and Federal Reserve, the “Agencies”) released a set of proposals that would significantly recalibrate U.S. bank capital requirements across banking organizations of all sizes, including:

Moore & Van Allen attorneys Kate Wellman, John Stoker, and Neil Bloomfield have published a new Law360 Expert Analysis, “Recent Bank Resolution Filings Stress Readiness Over Docs,” examining what recent bank resolution plan filings reveal about how institutions and regulators are approaching preparedness. 

Tiffany Payne explores this topic in a recently published article in Dow Jones Risk Journal: “State False Claims Laws: An Overview of the Evolving Landscape and Recent Enforcement Trends.”