Sitemap

On July 4, 2025, President Trump signed H.R.1, The One Big Beautiful Bill Act into law. Among the many, many other things that the law does, it dramatically reduces the amount of funding available to the Consumer Financial Protection Bureau (CFPB). Under the Dodd-Frank Act of 2010, the CFPB could request from the Federal Reserve up to 12% of its total operating expenses in 2009. Each year, the 2009 amount is adjusted for inflation to determine the new amount of the CFPB’s maximum permissible withdrawal from the Federal Reserve. Under H.R.1, this cap has been reduced from 12% to 6.5%, a reduction of nearly half of the CFPB’s annual funding. Senate Republicans claim that the reduction in funding for the CFPB will save taxpayers around $2 billion. Under the temporary leadership of Russ Vought, we’ve seen the CFPB withdraw nearly 70 guidance documents, de-prioritize enforcement of its payday lending rule, vacate its credit card late fee rule, stop defending a number of rules in federal court, and terminate several pending enforcement actions for alleged violations of consumer financial protection law. All this to say that a 46% reduction in its annual budget shouldn’t be too difficult for the lame duck agency to manage.

Under 31 CFR 1020.220, a financial institution's Customer Identification Program (CIP) requires the collection of certain information in connection with the opening of a new account. Specifically, the rule requires the financial institution to collect the following from the customer : Name Date of birth (for an individual) Residential or business street address, and Identification number (e.g., taxpayer identification number) Under an order issued by the Financial Crimes Enforcement Network (FinCEN) on June 27, 2025, financial institutions are now permitted to collect a customer's taxpayer identification number (TIN) from a third-party, instead of directly from the customer. To utilize this alternative collection method, the financial institution must have written procedures that: a) enable the financial institution to obtain the customer's TIN prior to account opening, b) recognize the relevant risks associated with obtaining the customer's TIN from a third-party, and c) enable the financial institution to form a reasonable belief that it knows the true identity of the customer. Nothing in the order requires the financial institution to utilize this alternative collection method.  You can access a copy of the FinCEN order here .