The Government Updateis issued by the Innovative Payments Association twenty times a year as a service to members. Editors: Brian Tate, President and CEO, IPA; Ben Jackson, COO, IPA; Eli Rosenberg, Partner, Baird Holm LLP; and Gray Derrick, Partner, Baird Holm LLP. Please address comments and suggestions to: [email protected].  2025 IPA Compliance Boot Camp The 2025 Compliance Boot Camp will take place on September 11, 2025, at Discover’s downtown offices in Chicago. CLE Credits will be available to attendees. This immersive educational opportunity will advance your compliance knowledge and help you navigate the complexities of our industry. What You Can Expect:
2025 Agenda:
Ready to register? Secure your spot today! We look forward to seeing you in Chicago this September!  2025 Fall Congressional Schedule
Jonathan Gould Sworn in as Comptroller of the Currency On July 10th the U.S. Senate voted to confirm the nomination of Jonathan Gould to be the new Comptroller of the Currency. , Prior to his confirmation Gould was a partner at Jones Day. Please note that Gould also served at the OCC in previous Administrations where he was the Senior Deputy Comptroller and Chief Counsel of the Office of the Comptroller of the Currency (OCC). You can read Gould’s complete bio at: https://www.jonesday.com/en/lawyers/g/jonathan-gould?tab=overview Michelle Bowman Confirmed to be Next Fed Vice Chair of Supervision Michelle Bowman has been confirmed as the next Vice Chair for Supervision role at the Federal Reserve. Bowman, who was already a member of the Federal Reserve Board, fills the post vacated by former Federal Reserve Governor, Michael Barr, who stepped down from the post February 28. Bowman will serve a four-year term. Senate Finance Reviews McKernan Nomination for Treasury Undersecretary On May 9th U.S. Secretary of the Treasury Scott Bessent announced that President Trump would nominate Jonathan McKernan to serve as the Undersecretary of Domestic Finance at the U.S. Department of the Treasury. Since the announcement the President has withdrawn McKernan’s nomination to lead the CFPB. McKernan has been an advisor at the Treasury Department while awaiting Senate confirmation to lead the Bureau of Consumer Financial Protection. McKernan previously served on the Board of Directors of the Federal Deposit Insurance Corporation and held senior roles at the Federal Housing Finance Agency, the U.S. Senate, and the Treasury Department. Before his government service, McKernan was an attorney in private practice focused on banking and consumer finance laws. McKernan’s nomination is expected to be reviewed by the Senate Finance Committee. McKernan’s nomination is likely to continue to move forward when the Senate returns after Labor Day. Reconciliation Bill Signed Into Law - Remittance Tax and CFPB Funding On July 4th President Trump signed the Reconciliation bill into law. Amongst the voluminous bill’s tax provisions are provisions that would add a 1% tax on all remittances. It is important to note that remittances initiated by a bank, or debit/credit card, are exempted. The law also includes language that reduces the CFPB’s access to funding from the Federal Reserve from 12% annually to 6.5%. Stablecoins In July 2025 the President signed the Genius Act into law. The version which ultimately made it through Congress was the Senate version supported in part by U.S. Senator Tim Scott (R-SC), the Chair of the Senate Banking Committee. It permits digital asset providers to create a money market-like fund for digital assets. This fall Congress will be working on a larger crypto ecosystem market structure bill that will seek to provide a regulatory framework for all digital assets. CFPB’s 1033 Redux The CFPB’s Open Banking Final Rule has been subject to debate since it was released last year. The rule implements Section 1033 of the Dodd-Frank Act. It would have significantly expanded consumer access to their financial data. A day after the final rule’s release, the Bank Policy Institute challenged the rule in court. Earlier this year, the Financial Technology Association intervened in the case to compel the CFPB to enforce the rule developed by the Biden Administration. At the IPA’s 2025 Innovative Payments Conference, Mark Calabria (Office of Management and Budget), announced that the CFPB would withdraw and restart its rulemaking regarding 1033, aka the Open Banking Rule. Shortly after Calabria’s statement at the IPC, the CFPB filed a motion in federal court announcing that “[a]fter reviewing the Rule and considering the issues that this case presents, Bureau leadership has determined that the Rule is unlawful and should be set aside.” In a recent Court hearing on July 29th the CFPB requested, and received from the Court, a stay to develop a new rule (or an amendment). The CFPB stated that they would like to have a release a rule within three weeks. If and when a new proposal is released by the CFPB, the IPA will review the new proposal alongside our members. In the interim, if you have any questions, please contact Brian Tate ([email protected]). FDIC Updates Approach on Pre-Populating On August 5th the FDIC announced it is updating its supervisory approach regarding whether an FDIC-supervised institution can use pre-populated customer information for the purpose of opening an account to satisfy Customer Identification Program (CIP) requirements. In short, it is the FDIC’s position that the requirement to collect identifying information “from the customer” under the CIP rule does not preclude the use of pre-filled information. Further, under the FDIC’s interpretation, a financial institution could use information from current or prior accounts or relationships involving the bank or its agents, or other sources, such as parent organizations, affiliates, vendors, and other third parties to pre-fill information that is reviewed and submitted by the customer. IPA Comment Letters Filed in 2025 (to date)
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