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Four key questions about Trump’s call for a 10% credit card interest rate cap
By Tod Gordon, Andy Kampf, Frank Mastrangelo, and David Simon Americans are carrying $1.233 trillion in credit card debt as of the third quarter of 2025, up from $1.209 trillion in Q2 2025 and the most since the New York Fed began tracking the data in 1999. Credit card payments are a burden for many American consumers, which is why calls for limits or caps in some form have come from voices on the left as well as the right . Well-meaning policy initiatives can have unexpecte
Andy Kampf
Jan 222 min read


A little short of GENIUS: did Congress adequately protect stablecoin holders from issuer insolvency?
by Michele Alt, Roman Goldstein, and Patrick Haggerty To protect stablecoin holders from issuer insolvency, GENIUS: Requires an issuer to hold full and segregated reserves against all its outstanding stablecoins; Provides holders of stablecoins issued by a nonbank issue r a superpriority claim in bankruptcy on those reserves and the issuer’s other assets; and Prescribes a non-bankruptcy resolution process for any insolvent bank issuer . Congress, however, overlooked a few imp
Michele Alt
Dec 1, 20256 min read


Five Questions about FinCEN’s Suspicious Activity Reporting Requirements(SARs)
On October 9, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) and the primary federal banking agencies issued “FAQs Regarding Suspicious Activity Reporting Requirements” to clarify four specific provisions that many financial institutions have incorporated into their Bank Security Act and anti-money-laundering (BSA/AML) programs to reduce the burdens related to SAR filings. We’ve summarized the FAQs below to help financial institutions un
Sepideh Rowland
Nov 12, 20255 min read


A Bank Charter Primer
What kind of bank charter is best? As Peter Renton and I discussed recently on the Fintech One on One podcast , the attitude in Washington has changed dramatically with the new administration, and there’s renewed interest in and optimism around bank charters. Here’s a quick run-down on what the options are. Build (De Novo) vs. Buy (Acquisition) : The important thing is that at this point there’s no difference in approvability: the regulators will look just as hard at an acqu
Michele Alt
May 28, 20253 min read
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