ALTERNATIVE FINANCIAL SERVICE PROVIDERS ASSOCIATION

a Community of 10,834 and Growing!

Edition: March 5, 2026

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New York publishes Buy Now, Pay Later Rules: by John D. Socknat & Joseph J. Schuster 


The New York Department of Financial Services has published proposed rules governing Buy Now, Pay Later (BNPL) financing plans operating in the state.


The proposal, among other things, would require BNPL providers to register with the state. The regulations implement a law signed by Governor Kathy Hochul as part of her FY26 budget plan.


Some states have been studying how to fill a void created in May, when the CFPB said it no longer would prioritize enforcement of BNPL rules. And advocates say that New York law could provide a model for BNPL enforcement.


“Too many New Yorkers have learned the hard way that some ‘Buy Now, Pay Later’ products are designed to trip them up with junk fees and overly burdensome fine print instead of helping them build a stable financial future,” Hochul said, in announcing the rules. “These new nation-leading regulations ensure that lenders know we have clear disclosures, limits on fees and real oversight so families don’t get pushed into a debt spiral while big financial companies cash in.”


Read more at Ballard Spahr L.L.P.

Beyond Banks: Trust Among the Financially Underserved


In 2023, over 18 percent of US households were either unbanked or underbanked, a group commonly referred to as financially underserved (e.g., see Burhouse, Navarro and Osaki (2016)). Prior work and survey evidence identify a lack of broad-scope trust in banks as an important reason for financial exclusion (e.g., FDIC (2024), Falcettoni and Nygaard (2025), and Xu (2020)). Yet it is not clear whether this mistrust is unique to banks or whether it extends to other institutions, such as government entities or nonbank providers of account services. This distinction matters for policymakers when considering how to serve this segment of the population. If mistrust is specific to banks, then alternative providers of account services — such as nonbanks or government entities — could improve access to the financial system. But if mistrust extends to alternative providers, then financial education or other trust-building initiatives might be more effective at increasing financial inclusion.


To address this gap, we designed our own surveys and fielded them to a sample of unbanked and underbanked individuals in the US. We elicited their levels of trust in various institutions, including different types of banks, government-related entities, and alternative payment providers. Using principal component analysis, we identify three dominant components of the trust scores which we label, in descending order of importance: (1) broad-scope trust, (2) concerns about traditional financial institutions, and (3) preference for a physical business presence. We explore how sociodemographic characteristics, including income, age, education, race and political affiliation, affect these components of trust.


Read more at Federal Reserve Bank of Cleveland

Payments Systems Research and Engagement


Engaging in payments systems research to promote innovative services provided by payments systems operators and financial institutions to consumers and businesses.


The Federal Reserve Bank of Cleveland payments experts conduct payments systems research and engagement independently and in partnership with Federal Reserve System colleagues. We aim to harness local payments expertise derived from payments work conducted at the Cleveland Fed and across the Fourth Federal Reserve District to advance payments systems knowledge.


We seek to enhance the understanding of the public, System colleagues, and financial services organizations that develop and use leading payments solutions for consumers and businesses. This advances the Federal Reserve System policy goal of promoting a safe, efficient, inclusive, and innovative payments system.


Payments systems impact our community and the economy

The Cleveland Fed is a thought leader in developing modern payments solutions. Beyond their operational responsibilities, Cleveland Fed staff have conducted and contributed to recent research focused on a variety of topics, including privacy-enhancing technologies, core banking systems, and digital currencies.


Read more at Federal Reserve Bank of Cleveland

Bridging the Credit Gap: The Case for a Pro-Innovation Fintech Framework


Technological innovation in consumer finance is a primary driver of competition and financial inclusion in the U.S., and modern products such as Buy Now, Pay Later (BNPL), need fair and balanced regulations to offer benefits to consumers and foster innovation.


To ensure that emerging tools like BNPL continue to expand consumer choice and drive market evolution, a balanced regulatory framework is essential — one that protects users without stifling the very innovation that empowers them, according to a research paper from Todd Zywicki, professor of law at George Mason University’s Antonin Scalia Law School. Zywicki also previously served as chair of the Consumer Financial Protection Bureau Taskforce of Consumer Financial Law.


“Fintech’s benefits accrue most strongly to consumers historically underserved by the traditional financial system, including younger, lower-income, rural, and minority households,” Zywicki writes in the paper, Facilitating Fintech’s Future: How Congress and Regulation can Support Innovation in Fintech, Earned Wage Access and Buy Now, Pay Later Products. “Drawing on a broad range of empirical research, it shows that fintech products increase access to credit, reduce reliance on high-cost alternatives, lower transaction costs, and mitigate demographic disparities in pricing and approval rates.”


Read more at ACA International

BofA Tracked Credit and Debit Spending By Generation—How Do You Stack Up?


Key Takeaways

  • U.S. card spending per household rose 2.4% year over year in October and 0.3% from the previous month (the fifth straight increase), with payments for services leading the way.
  • Older Americans are driving more of the growth, with Boomers outpacing younger groups in card-spending growth.
  • The number of retail transactions has dropped since January, suggesting price increases, not more purchases, are driving the gains.


Americans are swiping their cards more than ever heading into the holidays, but the story behind the increased spending reveals a stark generational divide, as well as a trend that could put the squeeze on your wallet.


Total credit and debit card spending per household jumped 2.4% year-over-year in October, marking the strongest growth in almost a year, according to Bank of America's latest monthly report tracking millions of card transactions.


But even as spending grew, the actual number of retail purchases declined, suggesting that inflation is taking a bite as Americans are paying more but getting less.


Read more at INVESTOPEDIA

Women’s wealth is expected to boom: Where they are investing and how they can maximize returns


Key Points

  • Cerulli Associates sees $105 trillion in wealth getting passed down to heirs through 2048.
  • Women’s investable assets in the U.S. are expected to nearly double by 2030, the consulting firm found.
  • Women should make sure they have the right balance of risk in their portfolio in order to maximize wealth.


Women investors are stepping up their game, gaining confidence and taking some more risks. Yet they still lag their male counterparts when it comes to the amount of money they are putting to work in the market.


But women are expected to see an influx of wealth as part of what is being coined the “Great Wealth Transfer.”


Cerulli Associates anticipates $105 trillion in wealth will be passed down to heirs through 2048, with about $54 trillion of that inheritance going to spouses. Women, on average, live nearly 6 years longer than men, according to the Centers for Disease Control and Prevention. That makes them more likely to be the prime recipients of that wealth.


Read more at CNBC

Have a tax law question?

Our #IRS Interactive Tax Assistant has answers.

Watch this short video to learn more:

https://youtu.be/y6HkaBkdKdU


The #IRS has launched a new web page to report suspected tax fraud and scams confidentially all in one place. Learn more on the new streamlined process: https://ow.ly/qJgX50Ymwgg


Reporting tax scams and fraud to the #IRS just got easier thanks to the launch of a new web page. Now you can report suspicious tax-related activities all in one place. Read more: https://ow.ly/qJgX50Ymwgg


Jose L. Santiago

Public Affairs Specialist

Tax Outreach, Partnership and Education

Emailjose.l.santiago@irs.gov

Debit card fraud losses rise


Dive Brief:

  • Fraud loss rates have climbed for debit cardholders, according to a Kansas City Federal Reserve Bank analysis issued Wednesday that is based on Federal Reserve Board data released in December. The actual loss rates detailed in the report differed depending on whether the transactions moved over a dual-message network, like that offered by card giant Visa, or a single-message network, such as Star or NYCE.
  • That 2023 data set for non-prepaid debit fraud showed the loss rate for cardholders rose over 2021 when debit cards were used to pay for goods or services online or in stores. Meanwhile, it wasn’t always the case that the loss rates rose for merchants and card issuers, according to the Kansas City report comparing 2021 and 2023 data.
  • Overall, the incidence of debit card fraud climbed for e-commerce purchases between 2021 and 2023, but in some cases in-person fraud rates on debit card transactions declined during that period, the analysis said.


Dive Insight:

The Kansas City analysis dug into the debit data issued by the Federal Reserve Board in December as part of its biennial report on debit card use last year. That report rekindled debate over the central bank’s decision to reset a cap on debit card interchange fees that revolve to some degree around fraud rates.


Read more at PAYMENTS DIVE

More mixed views of consumer confidence create added headwinds for vehicle purchase plans


How consumers are really doing and feeling nowadays varies significantly depending on which measurement you are viewing.


Confidence is up, but so is stress.


While the Conference Board’s Consumer Confidence Index increased in February, the LegalShield Consumer Stress Legal Index (CSLI) rose 4.4% in the fourth quarter. This marked the third consecutive quarterly increase and pushed the index 10.4% above 2024 levels to its highest sustained point since early in the pandemic.


And Cox Automotive chief economist Jeremy Robb said vehicle purchase plans ticked down slightly in February but remain up 11.2% year-over-year, “suggesting sustained interest in vehicle purchases despite broader confidence weakness.”


Read more at AUTO REMARKETING

68% of Customers Want AI in Banking, But Not Where You Think They Do


Data about consumers’ embrace of AI for financial use cases has been coming in hot for a while now. Nearly 60% of those polled by JD Power in late 2025 said they occasionally use AI for banking and financial services, while 13% said they do so every day — an uptake rate approaching 73%. And a 2025 study by Experian revealed that most financial AI users are satisfied: Among consumers already employing AI for personal financial management, 96% reported positive experiences.


The challenge for banks and credit unions is that the vast majority of those turning to AI for financial use cases are seeking advice and guidance rather than day-to-day banking services. It’s a critical distinction: In the former case, an individual is proactively using an AI tool that they chose to solve a problem (or, likelier, answer a question) that they identified. In the latter, the institution identifies the “problem” or use case and it initiates the solution or response.


The respondents to JD Power’s survey, for example, cited researching savings strategies and investing advice, and budgeting and expense management, as the sorts of financial problems they have used AI to help solve.


Read more at The Financial Brand

Poll shows Americans feel no gains


A new Pew Research Center poll finds most Americans see little to no improvement in affordability under President Trump, despite his claims of falling prices and a strong economy. Economic indicators show inflation has cooled, but costs for essentials like housing, food, and healthcare remain elevated compared to when Trump took office. The disconnect between official data and public sentiment underscores the political challenge affordability poses ahead of the midterm elections.


Poll reveals deep affordability concerns

A January Pew Research Center poll shows Americans’ top economic worries are the costs of food, housing, and healthcare, with most seeing no improvement under Trump. CBS News reports that while consumer confidence has risen alongside job growth, many households still face high prices for essentials. Trump's proposals, including capping credit card rates, have yet to deliver tangible benefits.


State of the Union underscores affordability challenge

In his 2026 State of the Union, Trump declared inflation was falling and incomes rising, but largely repeated existing policies while adding modest new proposals.


Read more at MSN

Online Lenders Alliance Marks National Consumer Protection Week by Highlighting Year-Round Efforts to Combat Scams and Fraud in Online Lending

OLA Urges Consumers Seeking Online Loans to Know Signs of Scams and Fraud, Look for OLA Seal, and Use OLA’s Consumer Hotline to Report Issues


ARLINGTON, Va. (March 3, 2026)—With National Consumer Protection Week taking place this week (March 1-7), the Online Lenders Alliance is once again highlighting its ongoing efforts to protect consumers in the online lending marketplace from scams and fraud.


One of OLA’s core missions is to promote consumer protection and favorable outcomes by setting industry standards and best practices under which members operate to ensure that consumers are fully informed and fairly treated. Consumer protection is built into OLA’s Code of Conduct and Best Practices, and OLA maintains several year-round initiatives to identify and remediate scams and fraud.


One of these initiatives is an aggressive website monitoring program that scours the internet for misleading terminology regularly used by fraudsters and scammers looking to take advantage of consumers. Since this program was initiated in 2016, OLA’s efforts to police URLs have resulted in more than 849,000 violations flagged, with 97 percent of these violations resolved through OLA enforcement actions.


Consumers looking to report suspected fraud or get assistance navigating the online lending landscape can also use the OLA Consumer Hotline. To access this free resource, consumers can call 1-866-299-7585 or send an email to complaints@oladc.org. Last year, this hotline received more than 5,280 consumer calls, approximately 346 of which were complaints about fraud. These complaints are sent to the Federal Trade Commission.


Read more at Online Lenders Alliance

Is the US dollar’s reserve currency status eroding? BROOKINGS


The U.S. dollar has fallen around 10% on a broad, trade-weighted basis since the start of President Trump’s second term. This fall has come in short, sharp bursts that have been very unnerving. The first of these was in April 2025 in the wake of the chaotic rollout of reciprocal tariffs. The second came more recently in January 2026 during the World Economic Forum summit in Davos, when the U.S. escalated its rhetoric over Greenland.


The sudden and sharp nature of these falls is unusual for a currency that’s traded and used as widely as the dollar. The daily flow of transactions into and out of the dollar is massive, which should rule out sudden, sharp declines. The fact that such declines have taken place nonetheless has sparked debate whether the U.S. is losing its reserve currency status. This post looks at the IMF’s Currency Composition of Official Foreign Exchange Reserves (COFER) data, which survey the allocations reserve managers make to different currencies. Remarkably, there is very little indication that reserve managers are exiting the dollar, maybe for lack of obvious alternatives. As a result, the fall in the dollar we’re seeing is more likely of the benign variety, driven by expectations for growth and monetary policy in the U.S. vis-à-vis its trading partners.


Read more at The Brookings Institution

BofA’s New Awards Program is a Radical Play for Primacy. But Will It Work?


Is Bank of America building on the success of a longtime customer loyalty program that some see as the gold standard? Or is it leaving some consumers behind even as it expands rewards eligibility to include virtually any retail customer, while upping the benefits for premium groups?


What’s happening: Effective on May 27, Bank of America will sunset its 12-year-old Preferred Rewards program in favor of the new BofA Rewards program.


Preferred Rewards is unique in that it spans all of a customer’s retail banking products with the bank, rather than focusing solely on their credit card accounts. That cross-platform approach has been atypical for banking providers, and the new program maintains that element.


What’s changing: Preferred Rewards required customers to maintain a specific dollar amount of business with the bank. The new program now includes all customers, with no minimums.


Read more at The Financial Brand

2026 Banking Priorities Executive Report

Community financial institution leaders reveal their priorities, challenges and blueprints for success in 2026.


2026: Banking’s Next Frontier

Community Bankers Embrace an Era of AI and Increased Efficiency


The U.S. financial industry is entering a pivotal year. The pace of technological change, rising consumer expectations and growing risks are reshaping how community banks and credit unions operate.

Community financial institutions face intensifying pressure from multiple directions. Digital-first fintechs continue pushing upward from the low end of the market while larger banks continue moving down-market. High regulatory and compliance demands persist, while Gen Z and Millennials show less loyalty and greater digital expectations.


Despite these pressures, many financial institution leaders remain optimistic. From artificial intelligence (AI)—expected to have the biggest impact this year—and automation to digital-first payments and cybersecurity, they’re embracing tools to modernize operations, increase efficiencies, mitigate risks, transform data into personalized interactions and strengthen account holder relationships.


Read more at CSIWEB.COM

How Third-Party Card Programs Can Lighten Your Regulatory Burden


Credit card programs are among the most compliance-intensive products in banking. CARD Act rules touch virtually every operational layer, from underwriting and disclosures to billing, rate changes and collections. For community banks and credit unions, maintaining the systems, training and ongoing monitoring these requirements demand can strain limited resources.


That’s driving more smaller financial institutions to consider third-party card program partnerships. These programs can handle compliance, technology integration, customer service and fraud management. The Federal Reserve, Office of the Comptroller of the Currency (OCC) and FDIC issued risk management guidelines for community banks managing third-party relationships.


Now, community banks and credit unions are treating these partnerships strategically. Third-party partners can help turn compliance into a competitive edge by freeing up internal capacity for growth, product development and member experiences — the areas where these institutions can differentiate.


Read more at The Financial Brand

Customized Payment Processing and

Merchant Service Provider for Your Business EC

Hutchins Center Fiscal Impact Measure: BROOKINGS


Fiscal policy subtracted 1 percentage point from U.S. GDP growth in the fourth quarter of 2025, according to the Hutchins Center Fiscal Impact Measure (FIM). The FIM translates changes in taxes and spending at the federal, state, and local levels into changes in aggregate demand, showing the effect of fiscal policy on real GDP growth. Real GDP rose at an annual rate of 1.4 percent in the fourth quarter, according to the latest government estimate.


Last year’s six-week government shutdown lowered GDP growth by 1 percentage point in the fourth quarter, reflecting the furlough of employees and a decline in federal purchases. Other factors—the One Big Beautiful Bill Act (OBBBA), tariffs, and underlying trends in fiscal policy – largely offset each other. (See the Fiscal Impact Breakdown spreadsheet in the Downloads section).


We expect fiscal policy to add 2 percentage points to GDP growth in the first quarter of 2026. This reflects the reversal of the temporary effects of the government shutdown, which we assume will boost real GDP in the quarter by 1.3 percentage points, as well as the stimulative effects of the OBBBA on both purchases and taxes.


Read more at The Brookings Institution

Small Business Credit Survey


With changes in the small-business credit environment in recent years, Federal Reserve policymakers have an interest in understanding the impact of those changes on small businesses and their ability to obtain the credit they need to operate and grow. The Small Business Credit Survey (SBCS) helps to strengthen that understanding by asking the business owners themselves about their credit needs and experiences.


The SBCS is an annual survey of small-business owners that has been administered nationally since 2016 through a collaboration of the 12 Federal Reserve Banks. As of 2020, the national SBCS team leads the SBCS from the Federal Reserve Bank of Cleveland. For questions about the SBCS, please contact Hal Martin.


About the Survey

The SBCS is a convenience-sample survey conducted in partnership with business and industry associations, local agencies, and nonprofits. The survey captures the perspectives of business owners operating firms with fewer than 500 employees. The data are weighted using Census Bureau data to match the distribution of firms in the SBCS sample to the distribution of small employer firms (1–499 employees) in the United States by age of the business, industry, number of employees, census division, urban or rural location, and owner’s race, ethnicity, and gender. The SBCS is conducted each year in the fall, and reports on the results are released beginning the following spring.


Read more at Federal Reserve Bank of Cleveland

CLOSED TRANSACTIONS

  • 1. Specialty Finance Company. $50 million Senior Credit Facility
  • 2. Small Business Finance Company $25 million Senior Credit Facility
  • 3. Consumer Installment Lender. $240 million Forward Flow Agreement
  • 4. Cambridge Wilkinson Investment Bank Closes Sale of $80MM+ Consumer Loan Portfolio

Why Banks Are Rethinking Human Review in Dispute Operations


Banks have been using AI to flag suspicious transactions and score fraud risk for years. Those systems help prioritize work but still depend on human decision-making to move cases forward. Yet, fraud tactics continue to evolve, consumers have less patience for slow dispute resolution and chargeback volume keeps climbing, with global totals projected to reach 324 million by 2028 — a 2.7x increase over six years.


That combination is straining dispute operations. Manual reviews struggle to scale as transaction volume increases, regulatory requirements tighten and consumer expectations rise. Backlogs and delays increase operational costs and put customer trust at risk.


To address these pressures, financial institutions are turning to agentic AI. Agentic systems operate autonomously. Instead of flagging anomalies and stopping, agents can process disputes by gathering evidence, applying policy and acting within clearly defined boundaries.


The move toward agentic AI forces banks to decide where autonomy makes sense, what guardrails are needed and which dispute processes can move beyond human review without increasing ris


Read more at The Financial Brand

Small Businesses Remain Resilient, But Need Help on Cost Control, Digital Transformation and Succession Planning


Need to Know

  • 74% of SMB owners expect revenue increases over the next 12 months, down slightly from 78% in 2024 as business owners balance growth expectations against persistent economic uncertainties.
  • 79% of businesses maintained or grew revenues over the past five years, demonstrating resilience through pandemic disruption, supply chain challenges, and interest rate volatility.
  • 77% experienced cost increases averaging 18% over the past year, leading 76% to raise prices by an average of 12% — margin compression that challenges profitability and may constrain future investment.
  • 91% plan to adopt more digital tools over five years, with strong focus on more digital payment forms (52%), implementing AI (50%), improving employee workflows (47%), and digital-first marketing strategies (45%).


According to the 2025 Business Owner Report, recently published by Bank of America, business owners enter 2026 with steady, measured optimism about their prospects and economic conditions.


Read more at The Financial Brand

ATTN: Texas CAB Licensing Update – Transition to NMLS


The Texas Office of Consumer Credit Commissioner (OCCC) has officially shut down Credit Access Business (CAB) functionality in the ALECS system as part of the transition to the Nationwide Multistate Licensing System & Registry (NMLS).


CABs will begin the official transition process Monday, March 16.


For now, you can go here to access licensing documents and guidance on the NMLS transition: https://occc.texas.gov/industry/cab/licensing-forms/ 


A few important operational notes for the industry:

• If you were in the process of preparing a new CAB license application in ALECS but had not yet submitted it, those applications appear to have been deleted.

• If you currently have a CAB license application already under review, you will still be able to continue working through that application within ALECS.

• No new CAB license activity will be accepted in ALECS going forward.


Beginning March 16, all new CAB applicants will need to complete the entire licensing process through NMLS.


For existing CAB licensees, the transition application process will require several steps:

• Creation of an NMLS company account

• Creation of individual NMLS accounts for owners, control persons, and other required individuals

• Addition of branch locations (if applicable)

• Assignment of branch managers


Each of these steps involves its own process of data entry, document uploads, and attestations to properly link all company, individual, and branch records within NMLS.


Another notable change: OCCC reporting will no longer occur through ALECS. At this time it has not yet been announced what system will ultimately handle CAB annual and quarterly reporting going forward.


For many of us who have worked in Texas consumer lending for years, ALECS has been a simple — if sometimes quirky — system. We learned its nuances, its shortcuts, and its occasional roadblocks.


Now we begin working inside NMLS… which of course has its own set of complexities.


CAB Consulting assisted many Regulated Lenders with this same transition last Summer and has already begun working with Texas CABs to get ready for this process. Reach out for more information see below for contact.


Best,

Michael Brown

Principal: CAB Consulting

Email: Michael@CreditAccessBusiness.com

Direct: 214-293-8676

www.CreditAccessBusiness.com

Owner: Star of Texas Financial Solutions

www.StarOfTexasFinancial.com

President: Texas Organization of Financial Service Centers

Watch Your Business Skyrocket.

More Visibility. More Customers. More Loans J

How Crypto Platforms Are Turning Education Into a Wealth-Building Engine for Young Investors


Young crypto investors aren’t just chasing upside anymore. While they remain open to innovation and calculated risk, what increasingly defines this generation is a deliberate effort to understand the mechanics behind digital assets from market structure to token economics to on-chain strategy.


In response, leading crypto platforms are doubling down on financial literacy as a core growth lever. This shift signals a maturation of the industry: education is no longer a side feature, it’s becoming foundational infrastructure for sustainable adoption in 2026 and beyond.


Binance CMO Rachel Conlan discussed the importance of financial literacy in the digital asset ecosystem while at the WEF in Davos recently, “Education is at the heart of Binance’s mission to democratize access to crypto globally. We invest heavily in accessible, multilingual educational content and programs. If crypto is going to reach the next billion users, education must evolve alongside the product.” Conlan continued, “The results speak for themselves: Binance now serves over 300 million users across 100+ countries.”


Read more at Haute Media Group

How M&A Readiness Is Fueling Bank Modernization


Truist burned $5 billion and five years trying to merge two banks. TSB locked out 1.9 million customers for five days in a catastrophic integration meltdown. They're not cautionary tales for retail banks. They're previews of the turmoil coming for legacy tech-dependent banks when the M&A gate reopens — unless they get their houses in order now.


In the past decade, the void created by institutions pulling away from relatively undesirable market segments, notably retail customers and SMEs, was profound. Challengers have been battling to fill the gap, winning large swaths of the market as institutions focus on large corporates and HNWIs.


The specific implications of this industry shift have been covered. Institution’s replacement of legacy systems with modern alternatives has spurred enormous growth in the BaaS segment of the fintech ecosystem, and institutions’ launch of their challengers (most abandoned within a few years) has demonstrated the scale of the neobank assault.


However, this fragmentation of the banking industry and expansion of the number of participants has fueled another trend: modernization to enable M&A.


Read more at The Financial Brand

Which U.S. religious groups are most highly educated? PEW


Hindus and Jews are much more likely to have a four-year college degree than Americans in other religious groups, according to Pew Research Center’s 2023-24 Religious Landscape Study (RLS).


Seven-in-ten Hindus and 65% of Jews have a bachelor’s degree or more education. That compares with 35% of U.S. adults overall.


On the other end of the spectrum, lower shares of evangelical Protestants (29%) and members of historically Black Protestant denominations (24%) hold college degrees. The shares of college graduates for several other religious groups range from 35% to 45%.


Educational differences by Christian subgroups


Read more at Pew Research Center

Fed requests comment on plan to remove reputation risk from supervision of banks: by Ballard CFS Group


The Federal Reserve is requesting comments on a proposal to remove reputation risk from the supervision of banks it oversees. Comments on the Fed proposal are due April 27, 2026.


“We have heard troubling cases of debanking—where supervisors use concerns about reputation risk to pressure financial institutions to debank customers because of their political views, religious beliefs, or involvement in disfavored but lawful businesses,” Vice Chair for Supervision Michelle W. Bowman said in a statement. “Discrimination by financial institutions on these bases is unlawful and does not have a role in the Federal Reserve’s supervisory framework.”


The Fed has defined reputation risk as “the potential that negative publicity regarding an institution’s business practices, whether true or not, will cause a decline in the customer base, costly litigation, or revenue reductions.”


Read more at Consumer Financial Services Group at Ballard Spahr LLP

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