Fintech 2026

USA – WASHINGTON

Canada

Seattle

Washington

Trends and Developments Contributed by: Blank Rome LLP

Olympia

Oregon

Blank Rome LLP 1825 Eye Street NW Washington, D.C. 20006 USA Tel: +1 202 420 2200 Fax: +1 202 420 2201

Introduction For the fintech industry, 2025 was a volatile year filled with a mix of uncertainty and opportunity. Federal priorities shifted overnight to a sweeping deregula - tory agenda: enforcement was largely shut down, the Biden administration’s focus on addressing redlining and other discriminatory practices was cancelled, and the new administration openly embraced digital cur - rencies as a viable financial product. However, per - ceiving a regulatory void, several states jumpstarted their own initiatives to counter federal deregulation, while the absence of the Chevron deference frame - work has also led to courts taking on technical ques - tions of statutory interpretation typically reserved for professional regulators, leaving fintechs and other regulated companies with arguably less certainty than ever. Another defining aspect of 2025 was the artificial intel - ligence (AI) boom that continues to drive automation and new product innovations, from sophisticated underwriting models, to generative output, agentic functions and fraud prevention, among other things. AI continues to permeate the entire fintech industry. As we discuss in this article, 2026 is likely to see some of these trends relating to regulatory reform slow down and possibly start to reverse by year-end. However, the rapid growth of AI and the evolving regulatory landscape for digital assets, among other things, are

likely to continue through the year and beyond. State initiatives to plant their own flags around regulation and consumer protection and increased civil litigation are likely here to stay. The State of the Regulators The second term of President Donald J. Trump unleashed a rapid and extensive deregulatory agenda. Almost immediately, there was a direct challenge to independent agencies, particularly the Consumer Financial Protection Bureau (CFPB), but also the attempted firings of Democratic-appointed members of the Federal Reserve Board (FRB), the Federal Trade Commission (FTC), and the National Credit Union Administration (NCUA), among others. But there were also smaller changes at the federal banking regulators that may be just as impactful on the regulatory land - scape in the year to come. Consumer Financial Protection Bureau The Trump administration moved quickly to install Project 2025 architect and outspoken CFPB critic Russell Vought as the Acting Director of the CFPB, and, under Acting Director Vought, attempted to shut - ter the CFBP altogether. Vought attempted to remove the CFPB’s funding, cancel its lease for office space, terminate over 90% of its staff, and transfer enforce - ment of the statutes under CFPB’s purview to the Department of Justice.

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