February 2024 Regulatory Round-Up

As February already begins to wind down and all of us are wondering what we might have missed so far this year, here is a round-up of additional regulatory activities in financial services:

• CFPB Publishes Updated Supervisory Procedural Rule. On February 16^th, the Consumer Financial Protection Bureau ("CFPB") published an updated supervisory procedural rule that revises the process supervised institutions must follow when they want to appeal compliance ratings and exam findings. This is the second revision since the CFPB first issued this procedural rule in October 2012, with the last revision occurring in 2015. Effectively, the revised rule provides more flexibility for both the CFPB and the supervised entities. The CFPB now has the ability to pull "potential members of the appeals committee" broader pool that includes "any CFPB manager who did not participate in the underlying matter being appealed and who has relevant expertise." Supervised entities may now