Banking Regulation to Watch in 2024

David Stein’s commentary was included in a Law360 article looking at what the most significant bank regulation matters will be in 2024. David provides insight on digital payments regulation by the Consumer Financial Protection Bureau (CFPB).

David specifically focused on a CFPB proposal to directly supervise so-called Big Tech companies that operate digital payment platforms. “That, in turn, could start to change how these tech firms approach their payment operations. Many of these digital payment services are offered by companies that haven't necessarily thought of themselves as financial institutions. There's a different mindset that follows from direct supervision. You're always thinking about the next exam and what the examiners will think....It can put more of an emphasis and premium on compliance,” he said.

He added that “the CFPB's examiners "are not limited to looking at just the activities that brought the entity under supervision. They can look at the whole range of activities that touch on consumer financial products and services. That can be somewhat intimidating for companies that may not be used to supervision."