The Office of the Comptroller of the Currency is working to ensure that banks will no longer be deputy regulators.
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In the past, banks have often found themselves deputized by the regulators to address concerns both inside and outside of banking. Perhaps the most famous example of this was “Operation Choke Point” that ran from 2013-2017. Banks were encouraged by examiners to avoid doing business in tobacco, firearms, and fossil fuels, for example on the basis of “reputational risk.” In an article in Compliance and Enforcement, lawyers from Davis Wright Tremain LLP point out that this was a departure from the “CAMELS (Capital adequacy, Asset quality, Management, Earnings, Liquidity and Sensitivity [to interest rate changes]) rating system, created in 1979.”

In February, Comptroller Jonathan Gould testified at a hearing in the Senate Banking Committee that the agency was moving away from including reputational risk as part of the examination process.

“We have also proposed a rule to eliminate reputation risk from supervision, a tool too often used to debank politically disfavored individuals or groups. We are intent on ensuring banks provide access to banking products and services based on individualized, objective, risk-based criteria, not politics or ideology,” Gould testified.

As in all things, the devil could be in the details on this. If the regulators began hunting for “debanking” as violation, then the pendulum could swing the other way as potential clients cry foul whenever a bank declines to work with them or offer them a loan. Institutions still need to be able to refuse business that doesn’t fit with their risk profile without the fear of “debanking” violations being used as a cudgel to force them to accept businesses.

In a cocktail hour conversation at the recent Innovative payments Conference, one bank lawyer explained to me that she had thought this through. The key for banks will be to explain why a particular business is not a right fit for the bank based on the banks’ risk profile, staffing levels to monitor loans, or similar bank-focused criteria.

When Comptroller Gould spoke at our conference, he also said that the OCC would no longer rely on banks to police every third party that touches the banking system. He said it was inappropriate for regulators to force third parties to do what the regulators want them to do.

Instead, he said that the regulators would be using their powers to supervise fintechs directly.

While it is rare for banking regulators to go after third-party partners directly, it is not without precedent.

In 2013, the FDIC imposed a consent order and civil money penalty on Achieve Financial Services, saying that it had the authority to do so because Achieve was an institution-affiliated party of its issuing bank.
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An “institution-affiliated party” of a bank under the Section 1813(u) of the Federal Deposit Insurance Act includes “any independent contractor (including any attorney, appraiser, or accountant)” that could violate a banking law. The act gives “the appropriate federal banking agency” the right to take actions against institution-affiliated parties directly.
Fintechs and other bank parties should be on notice that the regulators are looking their way. Compliance is an essential part of financial services, not just a check-the-box exercise.

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Washington enters another consequential week with lawmakers facing a crowded agenda and increasingly visible political divisions. Republican leaders in both the House and Senate are working to advance key legislative priorities while managing internal disagreements, a challenge made more difficult by competing policy demands and a rapidly evolving political environment.

Several issues will serve as important tests of congressional leadership in the days ahead. Debates surrounding the reauthorization of FISA Section 702 surveillance authorities, continued reconciliation efforts, and labor-related legislation are highlighting the complex dynamics shaping Capitol Hill. At the same time, primary elections and shifting political alliances are creating additional uncertainty as both parties look ahead to the November elections.
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In the Senate, lawmakers are balancing national security priorities, appropriations work, and confirmation votes, while House leaders face growing challenges in maintaining party unity on several high-profile issues. Committees in both chambers are also advancing legislation that could have long-term implications across multiple sectors of the economy, including financial services, technology, and digital assets.

For payments companies, fintechs, banks, and other stakeholders, these developments offer important signals about the policy environment taking shape in Washington. Legislative priorities, regulatory oversight, digital asset policy, and broader economic debates all remain in flux as Congress navigates a particularly active summer agenda.

Additional analysis, insights, and legislative updates are available exclusively to IPA members through the association's government relations resources. To learn more about IPA membership, visit www.ipa.org/join.

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​Congress returns to Washington this week facing a packed legislative agenda and mounting pressure to advance key priorities before the Memorial Day recess. Reconciliation negotiations, budget discussions, and high-profile policy debates are all converging at once, creating significant implications for financial services, digital assets, and the broader economy.

On Capitol Hill, lawmakers are navigating negotiations tied to federal spending, housing legislation, infrastructure funding, and executive branch nominations. At the same time, discussions surrounding market structure, digital asset oversight, and broader financial policy continue gaining momentum as policymakers work to advance bipartisan agreements on several unresolved issues.

International developments are also shaping the conversation in Washington. Recent meetings between President Trump and Chinese President Xi Jinping, ongoing trade discussions, and geopolitical tensions are expected to influence economic policy debates and regulatory priorities in the weeks ahead.

For the payments industry, these conversations represent more than political headlines. Decisions being made now could shape regulatory approaches, market conditions, and the future direction of financial innovation for years to come. IPA members receive deeper analysis and strategic insight into the developments shaping Washington and their impact on the payments ecosystem.

​Join the IPA to access exclusive member insights and stay ahead of the policy conversations shaping payments. 

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Congress returns this week facing an unusually compressed legislative window as Republican leaders push to advance key priorities before the Memorial Day recess. Lawmakers are balancing reconciliation negotiations, fiscal year 2027 spending measures, and high-profile policy debates that could carry significant implications for financial services, digital assets, and the broader economy.

In the House, leadership is expected to focus heavily on law enforcement messaging while navigating divisions within the Republican conference on issues including year-round ethanol sales and reconciliation spending priorities. At the same time, appropriators continue advancing funding legislation and administration officials are appearing before Congress to defend budget requests tied to defense, housing, and financial regulation.

The Senate is preparing for a busy week of nominations, reconciliation negotiations, and committee activity, including a closely watched markup of cryptocurrency market structure legislation. Discussions surrounding stablecoin regulation, digital asset oversight, and broader financial policy continue gaining momentum as lawmakers work to finalize bipartisan agreements on several unresolved issues. International developments, including an anticipated meeting between President Trump and Chinese President Xi Jinping, are also expected to shape economic and trade discussions in Washington.

For the payments industry, these developments represent more than political headlines. The decisions being made now could influence regulatory priorities, financial markets, and the future direction of digital asset policy for years to come. IPA members receive deeper analysis and strategic insight into the conversations shaping Washington and their impact on the payments ecosystem.
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Join IPA to access the full breakdown and stay ahead of the issues shaping the payments industry.

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​Washington returns this week under heightened tension, as policymakers respond to recent security concerns while navigating an already packed legislative agenda. Against a backdrop of global conflict and domestic uncertainty, Capitol Hill is balancing immediate priorities with longer-term policy debates that could shape the direction of key industries, including payments.

With a scheduled recess approaching, lawmakers are under pressure to make progress on several major issues, including budget negotiations, national security authorities, and critical funding measures. The urgency is amplified by deadlines tied to government operations and ongoing geopolitical developments, leaving little room for delay or disagreement.

In the House, leadership is working to advance multiple high-profile bills in a compressed timeframe, navigating tight margins and complex political dynamics. Meanwhile, the Senate continues to focus on nominations, budget discussions, and potential contingency plans if key legislation stalls. Across both chambers, committee activity remains intense, with hearings and markups offering further insight into policy priorities and regulatory direction.

Taken together, this week highlights just how interconnected policy, politics, and global events have become, and why staying informed is more critical than ever for the payments industry. For deeper insights and full analysis, join the IPA to access exclusive member content.

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Washington returns this week to a full agenda shaped by global instability, fiscal pressure, and mounting political stakes. The ongoing conflict in Iran continues to dominate the national conversation, with ripple effects across energy markets and economic policy. Lawmakers are increasingly focused on the domestic implications, particularly as rising costs become a growing concern for voters and a factor in the approaching midterm elections.

At the same time, Congress is navigating a series of complex legislative challenges. Efforts to resolve key funding disputes, particularly around homeland security and border enforcement, are expected to take center stage, alongside broader negotiations on surveillance authorities and other high-impact policy areas moving behind the scenes.

In the House and Senate, a busy stretch of hearings, budget discussions, and leadership decisions underscores the significance of this moment. With tight margins and competing priorities, even small shifts could have outsized impacts on the legislative path forward.

This is just a snapshot of the critical issues shaping the conversation in Washington right now. Join IPA to access the full breakdown and stay ahead of the issues shaping the payments industry.

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After a two-week recess, Congress is back in Washington facing the same high-pressure issues it left behind -- along with a growing list of new legislative priorities competing for attention.

At the center of the conversation: ongoing geopolitical tensions, a prolonged partial government shutdown, and mounting pressure around surveillance authorities, election policy, and congressional ethics. Lawmakers are stepping into a complex and crowded agenda where both timing and political strategy will shape outcomes in the weeks ahead.

Behind the scenes, critical budget discussions are ramping up as administration officials begin defending fiscal priorities on Capitol Hill. At the same time, movement on targeted funding measures and reconciliation strategies could influence how quickly key agencies, and broader government operations, move forward.

Meanwhile, both chambers are preparing for consequential votes and debates on issues ranging from national security authorities to immigration, environmental policy, and the balance of power within Congress itself. These near-term decisions are expected to set the tone for a broader legislative push that includes infrastructure, agriculture, housing, and digital asset policy later this year.

This is just a snapshot of what’s unfolding in Washington. IPA members receive deeper insights, real-time analysis, and strategic context to help navigate what’s next.
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Join IPA to access the full breakdown and stay ahead of the issues shaping the payments industry.

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Congress returns this week facing two major unresolved challenges ahead of the Easter recess: funding for the Department of Homeland Security (DHS) and the ongoing U.S. military conflict with Iran, now entering its fourth week. Senate Majority Leader John Thune (R-SD) has put senators on notice that the chamber will not break until the 38-day DHS funding standoff is resolved, while the House is expected to hold its own vote before departing Thursday.

The conflict with Iran also ​is raising serious questions about energy markets and national security spending. President Trump has submitted a $200 billion supplemental funding request tied to Iran military operations — a massive ask already sparking debate over the national debt, now at $39 trillion. Energy Secretary Chris Wright and Interior Secretary Doug Burgum will head to the CERAWeek conference in Houston this week, where industry leaders will be watching closely for signals on the conflict's duration and impact on energy prices.

In other key developments, President Trump announced a national AI framework last Friday, drawing swift praise from House Republicans who pledged a bipartisan push to advance the technology while protecting consumers. On the payments front, senators negotiating crypto market structure legislation with the White House are reporting progress, with a potential package that could be ready for committee consideration after the April recess.

Want intelligence like this delivered directly to you? This briefing is just one of the many exclusive benefits of IPA membership. The IPA keeps its members ahead of the policy developments that matter most to their businesses. Join today at ipa.org to gain full access.

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Congress returns to Washington this week for a short but important legislative window before both chambers break for the Easter recess. Lawmakers are navigating a complicated political environment as the partial government shutdown drags into its second month and international developments continue to influence economic and political messaging in Washington. The next two weeks will give policymakers limited time to move legislation before the spring break.
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In the House, leadership is expected to focus on a relatively narrow legislative agenda while committees begin ramping up activity tied to the upcoming budget and appropriations cycle. Several hearings and policy discussions scheduled this week may signal areas where lawmakers intend to focus in the months ahead, including issues relevant to financial services and data privacy.

The Senate, meanwhile, is preparing for a highly partisan debate on election-related legislation that could dominate the chamber’s floor time. Procedural hurdles and amendment votes are likely to stretch the debate across multiple days, highlighting ongoing tensions between the parties as the election cycle begins to shape the congressional agenda.

Outside Washington, key primary elections are also drawing attention as open congressional seats begin to reshape the political landscape ahead of the next Congress. These races are already attracting significant outside spending and could provide early signals about the policy priorities emerging in the next election cycle.

IPA members receive the full OGR Big Picture briefing each week with deeper insights into what these developments mean for the payments industry. Join the Innovative Payments Association to access the complete analysis and stay ahead of the policy and regulatory trends shaping payments