If you had “federalism” on your May bingo card, this is your week. Federal regulators doubled down on preempting state interchange laws. State regulators doubled down on a fair lending framework the federal regulators just walked away from. And the NCUA dropped a stablecoin proposal in between. The state-versus-federal scoreboard is more active than it has been in some time.

Here’s what moved.

NCUA Joins the OCC in Preempting State Interchange Laws (and Why That Matters in Albany)

• On May 19, 2026, the NCUA submitted an interim final rule (pending publication as of this writing) asserting that federal law preempts state laws restricting interchange fees, with the Illinois Interchange Fee Prohibition Act (IFPA) as the immediate target.
• The NCUA’s move follows the OCC’s April 24 interim final rule and order preempting the IFPA for national banks and federal savings associations. On May 8, the Seventh Circuit vacated the district court’s February 10 judgment upholding the IFPA and remanded the case for reconsideration in light of the OCC actions.
• For New York readers, or credit unions with members who travel to New York, this is not a faraway problem. The Association has been actively engaged on A.4017-A (Asm. McDonald)/S.5587-A (Sen. Skoufis), which would exclude state and local taxes and gratuities from the amount on which interchange is calculated.
• The OCC and NCUA preemption actions shield only federally chartered institutions. Any New York interchange bill that becomes law would still apply to state-chartered credit unions, leaving them to comply with restrictions that their federally chartered competitors are exempt from.
• Avoiding precisely this kind of split is a core reason the Association continues to engage directly with lawmakers in Albany.

NCUA Proposes Stablecoin Issuer Standards Under the GENIUS Act

• On May 15, 2026, the NCUA released a Notice of Proposed Rulemaking establishing operational and risk management standards for an NCUA-licensed Permitted Payment Stablecoin Issuer (PPSI).
• Chairman Hauptman noted the proposed standards are designed to align with those proposed for bank subsidiaries, with the explicit goal that credit unions face no disadvantage relative to banks if they want to participate.

NY Department of Financial Services Reaffirms Disparate Impact for State Chartered Institutions

• A NY DFS Industry Letter dated April 22, 2026 reminds state regulated entities that under New York Executive Law § 296-a, covered credit decisions that result in a disparate impact may still constitute unlawful discrimination in New York.
• This runs counter to both Executive Order 14281 (discussed here) and the CFPB’s final Regulation B rule, which scrubbed disparate impact references from the regulation and the Official Staff Commentary.
• DFS cites three prior consent orders and notes the letter does not impose new requirements; it is restating obligations that have always been there under state law.

Senate Banking Advances CLARITY Act

• On May 14, 2026, the Senate Banking Committee advanced the Digital Asset Market Clarity Act on a bipartisan vote.
• For credit unions, the bill would clarify custodial authority over digital commodities, permit stablecoin rewards (but not deposit-like yield), and create a clearer regulatory pathway for digital asset custody services.
• The bill still needs to be reconciled with the Senate Agriculture Committee’s version and clear a 60-vote Senate floor threshold.

Trump Nominates John Crews to NCUA Board

• On May 12, 2026, President Trump nominated John Crews, currently Deputy Assistant Secretary for Financial Institutions Policy at Treasury, to the NCUA Board.
• If confirmed by the Senate, Crews would replace Chairman Kyle Hauptman, who has been nominated by the SEC to the Public Company Accounting Oversight Board. Hauptman has said he intends to remain at the NCUA until a successor is confirmed.
• The NCUA Board has been operating with a single seated member since the firings of Todd Harper and Tanya Otsuka in 2025, both of whom are challenging their removals in federal court.

Let’s Make This Useful

I want this blog to be as relevant as possible to the people reading it. So:

• Got a topic you’d like me to break down?
• Burning desire to know more about that headline you read the other day?
• Have an industry-related question you want addressed?

Reach out to me at jeremy.newman@nycua.org. Let’s talk.

Until Next Time

From the big picture to the fine print, we’ve got you covered. Thanks for reading, and CU in the next post.

Spring has arrived in New York, and with it comes a fresh crop of economic crosswinds, regulatory developments, and federal budget drama that credit unions will need to navigate.

Here’s what’s moving and what’s looming.

Your Members’ Wallets: Tariffs, Energy Prices, and a Labor Market on Pause

If it feels like your members are getting squeezed from every direction right now, that’s because they are. A convergence of tariff policy, geopolitical disruption, and a sluggish labor market is creating real pressure on household budgets. And credit unions, as the original choice for affordability, are in a unique position to help.

The Iran conflict and energy prices

• The U.S.-Israeli military operations in Iran have disrupted the Strait of Hormuz, through which roughly 20% of the world’s oil supply flows, sending energy prices sharply higher
• The national average for a gallon of regular gas topped $4.06 as of April 1, the highest since 2022, with diesel at $5.45. For context, the national average was $2.81 per gallon in early January
• Contrary to the Federal Reserve (which forecasts inflation to hit 2.7% this year), the OECD projects U.S. inflation could reach 4.2% in 2026, well above the 2.68% average in 2025. The February Consumer Price Index came in at 2.4%, but economists expect the March reading (due April 10) to jump significantly as energy costs work through the economy
• Higher fuel costs hit low- and middle-income households hardest, acting as what Moody’s economists have called a “tax on households” that reduces real disposable income

Tariffs are still in the mix

• In February, the Supreme Court struck down tariffs imposed under IEEPA, ruling tariff authority rests with Congress. The administration imposed new Section 122 tariffs of 15% the same day
• Sector-specific tariffs on steel, aluminum, autos, pharmaceuticals, and copper remain in place under separate statutory authority
• Consumers are now bearing roughly 55% of total tariff costs, up from about 20% earlier in the cycle, as pre-tariff inventory buffers have been exhausted

The labor market: technically fine, actually flat

• The March jobs report showed 178,000 jobs added—well above the 59,000 expected—but the headline obscures a broader stagnation
• The economy has added just 260,000 total jobs over the past 12 months, an average of about 22,000 per month. Federal government employment continued to decline
• The unemployment rate edged down to 4.3%, but largely because nearly 400,000 people left the labor force. The number of workers who’ve stopped looking for jobs jumped by 144,000 in a single month
• Wage growth slowed to 3.5% year-over-year, the lowest since May 2021, while hours worked also declined
• With inflation above target and energy prices surging, markets expect the Fed to hold rates steady through the end of the year, with virtually no probability of a cut at the April FOMC meeting

What this means for credit unions

Add it up—higher gas prices, rising food costs, tariff pass-through, flat wages, and an uncertain job market—and your members are navigating the most challenging affordability environment in years. If they’re asking why everything costs more, the honest answer is: it’s complicated, and it’s coming from multiple directions at once.

But here’s the thing: this is exactly the environment credit unions were built for. Credit unions have been the OGs of affordability since long before “OG” was a thing. Lower loan rates, fewer fees, higher savings yields, and a not-for-profit structure that puts members first: that’s not a marketing pitch, it’s a business model. When a member’s household budget gets tighter, the difference between a credit union’s auto loan rate and a bank’s isn’t a rounding error. It’s a car payment they can actually make.

FY2027 Budget Proposal: CDFI Fund Cuts (Take Two)

• The White House released its FY2027 budget proposal on Friday, and for the second year running, it proposes cutting $204.5 million in discretionary awards for the Community Development Financial Institutions Fund
• Nearly 900 credit union branches serve as the sole financial institution in their census tracts making CDFI funding a lifeline, not a luxury
• The budget also includes an industry opposed administrative fee on lenders participating in SBA guaranteed business lending programs
• If this feels like déjà vu, that’s because it is. Last year’s budget attempted the same thing, and after the New York Credit Union Association and other industry partners fought these cuts, Congress ultimately funded the CDFI Fund for FY2026
• Expect the New York Credit Union Association to fight as fiercely for New York’s credit unions this time around

NCUA Releases 2025 Annual Report

• The NCUA released its 2025 Annual Report on April 1 and no, it wasn’t a joke
• Chairman Hauptman highlighted that the Share Insurance Fund and the credit union system remained well-capitalized with sufficient liquidity throughout 2025
• The agency touted “millions in cost savings” delivered to credit unions through its reorganization and efficiency efforts
• Key priorities carrying into 2026 include: the ongoing agency reorganization, GENIUS Act implementation, and developing a simplified regulatory framework
• The report documents NCUA’s performance against its 2022–2026 Strategic Plan, which is being replaced by the new 2026–2030 plan

NCUA Board Meeting: April 9

• The NCUA Board meets Thursday, April 9 (livestreamed here) with a packed agenda that includes:
  • Brokered and Reciprocal Deposits: A briefing on a topic that’s been a persistent pain point for credit unions managing liquidity. Watch for signals about whether the NCUA is considering regulatory changes in this space
  • Deregulation Project Update: The Board will review the ongoing deregulation initiative, now eight rounds deep
  • 2026–2030 Strategic Plan: The new strategic plan will set the agency’s direction for the next five years
  • 2026 Annual Performance Plan: How the NCUA plans to measure itself against those strategic goals

Mark Your Calendar: 2026 State Governmental Affairs Conference

Advocacy is a year-round effort, but this is the main event for New York’s credit union movement. The 2026 State Governmental Affairs Conference is coming up April 27–28 at the Renaissance Albany Hotel. This is your chance to connect directly with the lawmakers, regulators, and insiders who shape New York’s financial services landscape.

State-level legislative decisions increasingly affect every credit union in New York—state and federally chartered alike. If we’re not at the table, we’re on the menu. Registration closes April 22, so don’t wait.

Register here.

Let’s Make This Useful

I want this blog to be as relevant as possible to the people reading it. So:

• Got a topic you’d like me to break down?
• Burning desire to know more about that headline you read the other day?
• Have an industry-related question you want addressed?

Reach out to me at jeremy.newman@nycua.org. Let’s talk.

Until Next Time

From the big picture to the fine print, we’ve got you covered. Thanks for reading, and CU in the next post.

January has a reputation for being slow. Compliance, apparently, did not get the memo.

This roundup touches on some familiar themes for credit unions heading into 2026: credit cards, interchange pressure, supervisory priorities, and the ever-present possibility of a government shutdown, all unfolding at once.

Here is what’s moving, what’s stalled, and what deserves a closer look as we head toward the end of the month.

Government Shutdown Looms as DHS Funding Stalls

• Federal funding expires January 30, 2026, with Senate Democrats threatening to block the spending package over DHS funding disputes following fatal ICE shootings in Minneapolis
• The House passed $1.2 trillion spending package on January 22, but Senate opposition creates high shutdown risk

Credit Card Competition Act : Interchange Revenue Remains Under Threat

• Talk about Senators Durbin and Marshall introducing their revised Credit Card Competition Act as an amendment to crypto legislation in Senate Agriculture Committee were mitigated Monday afternoon
• However, attacks on interchange remain as the White House and various legislators continue to support the Credit Card Competition Act

10% Credit Card Rate Cap Moves from Social Media Post to Proposed Legislation

• What began as a social media post by President Trump proposing a one-year 10% APR cap has evolved into serious bipartisan legislation gaining congressional attention
• Senate bill S.381 by Sanders (I-VT) and Hawley (R-MO), and House bill H.R.1944 by Ocasio-Cortez (D-NY) and Luna (R-FL) propose five-year 10% caps with enforcement mechanisms
• America’s Credit Unions warns that an estimated two-thirds of credit card users carrying a balance would have their credit lines reduced or eliminated and virtually all of the 47 million Americans with a sub-prime credit score would be unable to obtain or keep a credit card

$8 Credit Card Late Fee Cap: From Dead CFPB Rule to Legislative Revival

• The Senate introduced the Credit Card Fairness Act to codify $8 late fee cap into federal law after CFPB’s rule was vacated in April 2025
• Current Regulation Z safe-harbor amounts remain in effect for now

NCUA Sets 2026 Examination Priorities

• The NCUA released its 2026 Supervisory Priorities Letter, emphasizing “No Regulation by Enforcement” while zeroing in on credit unions’ weakest loan performance in over a decade
• Examiners will focus on underwriting standards, credit risk management, and liquidity planning
• Operational risk remains a priority, with continued emphasis on fraud prevention and payment systems security and BSA makes an appearance after being off the list for a few years

Looking Ahead

The next few days are critical with committee hearings (weather dependent) and the end of the month government shutdown deadline.

Let’s Make This Useful

I want this blog to be as relevant as possible to the people reading it. So:

• Got a topic you’d like me to break down?
• Burning desire to know more about that headline you read the other day?
• Have an industry-related question you want addressed?

Reach out to me at jeremy.newman@nycua.org. Let’s talk.

Until Next Time

From the big picture to the fine print, we’ve got you covered. Thanks for reading, and CU in the next post.

If you were hoping for a breather, let me be the first to apologize for your dashed hopes.  From enforcement policy shifts to leadership changes at NY DFS, the regulators have kept things moving. Here’s what credit unions need to know—and how these updates might reshape the compliance landscape heading into Q4.

NCUA Doubles Down on “No Regulation-by-Enforcement” Policy

• Chairman Kyle Hauptman issued a formal policy statement reaffirming that enforcement should focus on “clear and significant violations” of existing law
• The policy reinforces that examination findings should be based on established rules, not examiner interpretation or agency wish lists
• This means no more surprise policy changes buried in enforcement actions; a welcome relief for credit unions tired of regulatory whiplash

Multi-Agency SAR Guidance Gets an FAQ Refresh

• NCUA, FDIC, Federal Reserve, OCC, and FinCEN released updated FAQs on Suspicious Activity Reports and AML/CFT requirements
• The four FAQs clarify requirements relating to structuring, continuing activity reviews, and decisions not to file a SAR

CFPB Extends Small Business Lending Data Compliance Dates

• The CFPB finalized its rule extending Section 1071 compliance dates
• The new timelines are: Tier 1—July 1, 2026, with first filing due July 1, 2027; Tier 2—January 1, 2027, with first filing due June 1, 2028; and Tier 3—October 1, 2027, with first filing due June 1, 2028.
• Lenders are in Tier 1 if they originated at least 2,500 covered loans in the preceding two years, Tier 2 if they originated at least 500 covered loans, and Tier 3 if they originated at least 100 covered loans. 
• Lenders can choose their origination look back period: 2022-2023; 2023-2024; or 2024-2025.

New York Department of Financial Services Gets New Leadership

• On October 18, Superintendent Adrienne Harris steps down after four years leading the department
• Kaitlin Asrow, current Executive Deputy Superintendent of Research & Innovation, becomes Acting Superintendent
• Expect NYDFS to maintain its tech-forward regulatory approach; Asrow’s background in fintech and virtual currency regulation suggests continuity in the department’s innovation initiatives.

Looking Ahead

Keep your calendars marked for October 21, 2025, when the Federal Reserve hosts its “Payments Innovation Conference.” Expect discussions on stablecoin use cases, AI in payments, and the convergence of traditional and decentralized finance. It’s the kind of forward-looking conversation that could signal where regulatory attention heads next. You can see the live broadcast at https://www.federalreserve.gov/default.htm or The Fed’s YouTube channel.

Let’s Make This Useful

I want this blog to be as relevant as possible to the people reading it. So:

• Got a topic you’d like me to break down?
• Burning desire to know more about that headline you read the other day?
• Have an industry-related question you want addressed?

Reach out to me at jeremy.newman@nycua.org. Let’s talk.

Until Next Time

From the big picture to the fine print, we’ve got you covered. Thanks for reading, and CU in the next post.

Happy National Compliance Officer Day to those who celebrate!

Another week, another round of regulatory cliffhangers. With the federal government careening towards a shutdown, flood insurance authorization about to lapse, and the CFPB rolling out an aggressive regulatory agenda, credit unions have plenty on their plates.  Oh, and don’t forget about that little rate cut that got a bit of news.

So, grab that second cup of coffee or chai and let’s break down what’s mattered for your credit union radar over the past couple of weeks.

Potential Federal Government Shutdown

Let’s hope this one stays theoretical and on Wednesday morning we can talk about how Congress passed an appropriations bill in the nick of time. 

Congress has until September 30 to pass appropriations bills for FY2026 or enact a continuing resolution to avoid a government shutdown. The House passed a short-term funding measure, but the Senate rejected it before they headed home for a one-week recess, scheduled to return September 29. 

Non-essential federal operations would halt, furloughing thousands of federal workers nationwide, including many in New York.

As with prior shutdowns, credit unions may serve federal employees through special loan programs, payment flexibility, and financial counseling services. Branches in federal buildings may face access issues.

Essential services and mandatory programs will continue, but regulatory approvals and federal agency disbursements could face delays.

National Flood Insurance Program Authorization Expires September 30, 2025

The NFIP’s authorization expires the same day as the government funding deadline, a double whammy for real estate markets.

During a lapse, borrowers will not be able to purchase new flood insurance contracts, but existing policies remain valid and claims—funds permitting—continue to be paid.

Credit unions must still conduct flood determinations and should provide required disclosures.

CFPB Releases Its Regulatory Agenda

The CFPB unveiled its Spring Unified Agenda with 24 regulatory initiatives. Here are some highlights:

Key Proposed and Pre-Rule Initiatives for Credit Unions:

• Personal Financial Data Rights (Section 1033): Open banking rule under reconsideration after being paused in July 2025.
• Small Business Lending Data Collection (Section 1071): Compliance dates already extended, but further revisions may be coming.
• UDAAP Rulemaking: Potential redefinition of unfair, deceptive, or abusive practices under Section 1031.
• Equal Credit Opportunity (Regulation B): Potential clarification of obligations imposed by the Equal Credit Opportunity Act.
• Mortgage Servicing Streamlining: Final rules expected to ease servicing for borrowers with payment difficulties.
• Fair Credit Reporting (Regulation V): Proposals addressing identity theft and coerced debt.

Wrapping It Up

Between a possible federal government shutdown, flood insurance uncertainty, and some ambitious rulemakings, credit unions have plenty to track before the calendar turns to October.  Add a dash of pumpkin spice and you’ve got a recipe for a Fall full of moving pieces.

Let’s Make This Useful

I want this blog to be as relevant as possible to the people reading it. So:

• Got a topic you’d like me to break down?
• Burning desire to know more about that headline you read the other day?
• Have an industry-related question you want addressed?

Reach out to me at jeremy.newman@nycua.org. Let’s talk.

Until Next Time

From the big picture to the fine print, we’ve got you covered. Thanks for reading, and CU in the next post.

Last week proved compliance news does not run on summer hours. Between the NCUA’s town hall, the CFPB’s ambitious (if blink-and-you-missed-it) rulemaking agenda, new AI guidance from NCUA, and NY DFS cracking down on cybersecurity lapses, the docket is full. Think of this roundup as your compliance espresso shot: strong, focused, and exactly what you need to stay alert.

NCUA Town Hall

The National Credit Union Administration (NCUA) will host a Strategic Plan Town Hall on Tuesday, September 9 from 2-3 p.m. Eastern.  The event invites credit union industry stakeholders to provide input on the NCUA Strategic Plan and the upcoming priorities of the agency.

Here is the link to register: Strategic Plan Town Hall registration – WebEx Enterprise Site

Now You See Me-CFPB Spring 2025 Regulatory Agenda

The CFPB published, and then quickly unpublished, its Spring 2025 Rulemaking Agenda. So, while there is not yet an official version of the Agenda, what we did see is plan with twice as many items as the Fall 2024 Agenda with a paradoxical focus on consumer protection and deregulation.

NCUA Launches AI Resource Webpage for Credit Unions

Following on its discussion of Artificial Intelligence at its July Board meeting, the NCUA unveiled a brand-new webpage packed with AI resources designed specifically for credit unions exploring or expanding AI usage. The hub covers areas like AI implementation, risk management, data security, use cases, and cyber-risk considerations.

The site is meant to guide credit unions through the often tricky terrain of vendor vetting, algorithmic transparency, fair lending safeguards, and privacy protections as you explore or enhance AI risk management practices.

NY DFS Enforces $2 Million Cybersecurity Settlement

The New York Department of Financial Services secured a $2 million settlement via consent order with Healthplex, Inc. for cybersecurity regulation violations, highlighting failures in phishing-resistant multi-factor authentication, risk assessments, and timely breach reporting.

While Healthplex is not a credit union, the message is crystal clear even if the DFS does not directly regulate your institution: regulators continue to focus on cybersecurity vulnerabilities and take an aggressive enforcement approach to compliance. 

Looking Ahead

With enforcement actions highlighting the importance of internal controls and cybersecurity compliance, new resources to help explore AI solutions, this is an excellent time for credit unions to review their risk management programs and ensure robust oversight of both employees and third-party partnerships.

Let’s Make This Useful

I want this blog to be as relevant as possible to the people reading it. So:

• Got a topic you’d like me to break down?
• Burning desire to know more about that headline you read the other day?
• Have an industry-related question you want addressed?

Reach out to me at jeremy.newman@nycua.org. Let’s talk.

Until Next Time

From the big picture to the fine print, we’ve got you covered. Thanks for reading, and CU in the next post.

Well, credit unioners, last week proved that even in the dog days of summer impactful activities never take a vacation. From federal courts shaking up interchange fee structures to state attorneys general taking aim at payment platforms, there’s plenty to keep your teams busy. Let’s dive into some of what happened while you were hopefully enjoying some summer downtime.

In other words, CU throughout the week. (Folks, I’m workshopping puns here. They can’t all be winners.)

Corner Post Strikes Again: Interchange Fee Regulation II Overturned and Stayed

• U.S. District Judge in North Dakota vacated the Federal Reserve’s Regulation II debit card interchange fee cap
• In short, the Court ruled the Fed unlawfully expanded allowable cost categories beyond statutory limits
• The decision is stayed pending appeals to prevent market disruption
• The ruling does not impact the Fed’s separate October 2023 proposal to further lower the cap

“Debanking” Gets the Executive Treatment

• President Trump signed the Guaranteeing Fair Banking for All Americans Executive Order, directing federal agencies, including NCUA and CFPB, to investigate “politicized or unlawful debanking” practices and regulations that could lead to account closures
• Emphasizes risk-based assessments should be “reasonable and apolitical”
• The EO mandates removal of “reputation risk” language from regulatory guidance

CFPB Reverses Course on Open Banking Rule

• CFPB announced it will issue a revised Section 1033 open banking rule rather than withdrawing it entirely as it previously announced
• It plans on an accelerated rulemaking process with advanced notice expected within three weeks
• Original compliance deadlines starting April 1, 2026, for largest institutions remain in flux

New York AG Sues Zelle Over Fraud Failures

• NY Attorney General Letitia James sued Early Warning Services (Zelle’s operator) alleging inadequate security measures enabled over $1 billion in consumer fraud losses between 2017-2023
• The suit alleges EWS prioritized rapid expansion over user security, leading to surge in unauthorized access and deceptive payment schemes
• AG seeks restitution for affected New Yorkers and demands implementation of stronger anti-fraud measures
• This lawsuit follows on the CFPB’s March 2025 dismissal of similar federal lawsuit

Mortgage Trigger Leads Bill Passes Congress

• On August 2nd, the Senate passed H.R. 2808, the Homebuyers Privacy Protection Act, will take effect 180 days after President Trump signs the bill into law, will significantly curtail the consumer offensive practice of mortgage trigger leads.
• Currently, when a consumer applies for a mortgage loan, the fact that they have done so is sold to other creditors by consumer reporting agencies. These other creditors then inundate the consumer with mortgage solicitations via call, text message, and/or e-mail. In many instances, the consumer is furious with their original creditor because they assume the fact that they applied for a mortgage loan was information that was shared by the creditor.
• Under the Act, a creditor will only be able to obtain a mortgage trigger lead from a consumer reporting agency if:
  • The creditor will be making a firm offer of credit to the consumer, and
  • The creditor submits documentation to the consumer reporting agency that it
    • Has authorization from the consumer to obtain his/her consumer report,
    • Originated the consumer’s residential mortgage loan,
    • Services the consumer’s current residential mortgage loan, or
    • Is an insured depository institution that holds a current account for the consumer.

Looking Ahead

Next week, keep an eye on the Federal Reserve’s response to the interchange fee ruling. The CFPB’s promised “accelerated” open banking rulemaking should also provide more clarity on data sharing timelines. And with the NY AG’s Zelle lawsuit making waves, expect increased scrutiny of P2P payment platform partnerships.

Let’s Make This Useful

I want this blog to be as relevant as possible to the people reading it. So:

• Got a topic you’d like me to break down?
• Burning desire to know more about that headline you read the other day?
• Have an industry-related question you want addressed?

Reach out to me at jeremy.newman@nycua.org. Let’s talk.

Until Next Time

From the big picture to the fine print, we’ve got you covered. Thanks for reading, and CU in the next post.