On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) announced its long-awaited final rule on “Personal Financial Data Rights” (the Final Rule). The Final Rule implements Section 1033 of the Dodd-Frank Act, which provides consumers the right to access and port their financial information between banks and other financial entities. For an analysis of the proposed rule, please see our analysis here.Continue Reading CFPB Releases Final Open Banking Rules: Key Takeaways for Fintech Companies

In a decision with far-ranging implications for federal administrative law, the United States Supreme Court issued its long-awaited ruling in Loper Bright Enterprises v. Raimondo (Loper Bright).1 The Supreme Court’s six-Justice majority held that the Administrative Procedure Act (APA) requires courts interpreting agency regulations to determine independently whether the agencies have acted within their statutory authority, even where the statute at issue is ambiguous. In so holding, the Court overruled its 1984 decision in Chevron USA v. Natural Resources Defense Council, which for the last four decades had governed thousands of cases involving federal agency interpretations of ambiguous laws.Continue Reading “Chevron is overruled”: How Loper Bright Will Change the Regulatory Law Landscape