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Financial Services News Roundup
April 3, 2025 – April 17, 2025

CFPB Announces Potential Relief From Registration Requirements for Small Loan Providers

Welcome to Goodwin's Financial Services News Roundup. Our newsletter highlights important legal, regulatory, and business developments related to financial services and banking.

In this issue
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0CFPB Announces Potential Relief From Registration Requirements for Small Loan Providers

On April 11, the Consumer Financial Protection Bureau (CFPB) announced that "it will not prioritize enforcement or supervision actions with regard to entities that do not satisfy future deadlines" under 12 CFR part 1092 - Registry of Nonbank Covered Persons (Nonbank Registration), enacted to create a central public repository for information regarding public agency and court orders imposed upon nonbank covered persons. Instead, the CFPB expressed its intent to focus its enforcement and supervision activities on "pressing threats to consumers" and to potentially issue a notice of proposed rulemaking to rescind the regulation or narrow its scope.

0FinCEN Renews Geographic Targeting Orders Involving Certain Real Estate Transactions

On April 14, the Financial Crimes Enforcement Network (FinCEN) announced the renewal of its Geographic Targeting Orders (GTOs), requiring US title insurance companies to report the beneficial owners behind legal entities involved in certain non-financed residential real estate purchases. Title insurers must verify and report identifying information for individuals who own 25% or more of a purchasing legal entity, even if similar data has been reported elsewhere. The renewed orders are effective from April 15 through October 9, 2025 and apply to transactions of $300,000 or more (or $50,000 in Baltimore) conducted without traditional financing and involving payment in part with cash, checks, wires, or virtual currency. Covered jurisdictions include major metropolitan areas across 14 states and the District of Columbia. Covered businesses must retain records for five years and may rely on third-party information in fulfilling compliance requirements. FinCEN emphasized that reporting obligations under the GTOs are distinct from those under the Corporate Transparency Act.

0FDIC Makes Temporary Electronic Communication Guidance Permanent

On April 15, the Federal Deposit Insurance Corporation (FDIC) announced that the temporary guidance it previously provided in March 2020 related to the preferred manner in which to contact the FDIC regarding supervisory matters (FIL-27-2020 and FIL-29-2020) will now be permanent guidance, as provided in instructions attached to FIL-9-2025. The March 2020 temporary guidance instructed financial institutions to use the FDIC's Secure Email portal to contact the FDIC with respect to supervisory matters. Many financial institutions have used the FDIC's Secure Email portal since the temporary guidance was issued, and the FDIC's announcement confirms that this method remains the FDIC's preferred contact method.

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