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October 29, 2025
Several policymakers raised concerns with media outlets in recent days about a loophole in the Genius Act that allows stablecoin issuers to avoid its prohibition on paying interest.
The Genius Act bans payment stablecoin issuers from paying interest or yield on payment stablecoins, but the restriction can be bypassed when exchanges or other affiliates offer yield or rewards to stablecoin holders. The American Bankers Association has called on lawmakers to strengthen the law by expanding the prohibition to cover digital asset exchanges, brokers, dealers and affiliated entities.
Several policymakers have expressed similar concerns. In an interview on the podcast Crypto in America, Federal Reserve Governor Christopher Waller said he views stablecoins as a pure payment instrument.
“It’s not an investment vehicle. It’s not a time deposit where you’re holding it to earn interest,” he said.
Sen. John Kennedy (R-La.) told Punchbowl News that bankers’ concerns about the loophole should be taken seriously. Sen. Mike Rounds (R-S.D.) told Politico Pro that the intent of the legislation was to ban yield payments to stablecoin holders.
“This looks to me like it’s an end-run on the original legislation,” Rounds said. “So I’ve got concerns with that.”
ABA Banking Journal: Court temporarily halts Section 1033 rule enforcement
October 29, 2025
A federal court today issued an order preventing the Consumer Financial Protection Bureau from enforcing its rule on financial data sharing while the bureau reassesses the regulation.
The 2024 rule implemented Section 1033 of the Dodd-Frank Act, which requires banks and other financial institutions to make a consumer’s financial information available to them or a third party at the consumer’s direction. The Kentucky Bankers Association joined the Bank Policy Institute and other plaintiffs in challenging the rule, arguing it jeopardized consumers’ privacy and account security.
The rule was implemented under the CFPB’s prior leadership. In separate court filings in May, both the plaintiffs and CFPB asked the U.S. District Court for Eastern Kentucky to vacate the rule. The CFPB has since issued an advance notice of proposed rulemaking seeking public input as it drafts a replacement for the rule.
In his order, District Judge Danny Reeves enjoined the CFPB from enforcing the 2024 rule until it has completed its reconsideration of the regulation.
“Ultimately, the CFPB is currently engaged in rulemaking to reconsider the rule considering the plaintiffs’ concerns about its lawfulness,” he wrote. “Nevertheless, the plaintiffs and their members are being compelled to incur expenses that would be unrecoverable and unnecessary if the new rule substantially revises the existing requirements or if the current rule is vacated.”
ABA responds
The court order affirms the serious concerns raised by the American Bankers Association and other stakeholders regarding the rule’s legal foundation, scope and impact on consumer privacy and data security, ABA President and CEO Rob Nichols said in a statement.
“The court’s decision provides a necessary pause for the bureau to engage meaningfully with stakeholders and address the rule’s significant flaws while ensuring banks don’t have to invest time and resources to comply with an overbroad and legally flawed rule that is actively undergoing substantial revision,” he said. “In the meantime, consumers will continue to reap benefits achieved without regulation thanks to industry standard-setting, innovation and partnerships that prioritize security, transparency and consumer control.”
ABA last week sent a comment letter to the CFPB offering the following recommendations to make the revised data sharing rule more effective than the 2024 version.
Full Article
ABA Banking Journal: Fraud Watch: Verifying Treasury checks before they’re cashed
With ABA’s every-increasing anti-fraud resources and training, bankers can save their banks and their customers a lot of money.
October 30, 2025 | Paul Benda and Hannah Ibberson

While the Trump administration has directed Treasury to significantly reduce the volume of Treasury checks in the coming months, modernization is still some distance off and will ultimately depend on how many exemptions are permitted.
For example, despite Treasury’s laudable effort to make Social Security payments electronically, the government is still issuing hundreds of thousands of paper checks just for Social Security beneficiaries. So we know Treasury checks are likely to be around at a significant volume for a while.
Most bankers who deal with U.S. Treasury checks know about the Treasury Check Verification System. It’s a mechanism for verifying Treasury checks online; anyone can check them by entering the amount and the check number. However, until recently, this system did not verify the name of the payee, which criminals took advantage of by washing or reproducing them with different names.
Having counterfeit checks that passed TCVS verification can be costly to banks. To address this, Treasury created a verification system with restricted access requiring an API. ABA volunteered to be a service provider for banks and provide access via the API as a free service for our members. Treasury quickly approved our application, and our team got on building the connection.
Earlier this year, ABA made this access live to bank members through aba.com/tcvs. Anyone from an ABA member bank can access the TCVS portal, which is currently configured to verify single checks. Some banks have access managed by their central fraud teams, and others have deployed TCVS access at the teller level to validate a Treasury check when it’s presented at the branch. It’s up to the banks to figure out how they want to deploy this tool.
In the first six weeks of public access, hundreds of banks had checked nearly 7,000 checks — and by July, banks were verifying $20 million worth of Treasury checks per day.
In addition to giving their employees access to ABA’s TCVS portal, many banks are pushing their tellers to get aba.com accounts to access free-to-members ABA Frontline Compliance Training, which includes courses on check fraud. ABA also offers a check fraud toolkit and the ABA Fraud Contact Directory, which includes inside contact info for fraud claims for half of all banks in the U.S., as well as credit unions — because when it comes to stopping fraud, time is of the essence.
With our TCVS access along with ABA’s other anti-fraud resources — and more in the pipeline — bankers can make a material impact on the flow of funds to criminals, and save their banks and their customers a lot of money.
This article is adapted from a recent ABA Fraudcast episode.
Paul Benda is EVP for risk, fraud and cybersecurity policy at ABA. Hannah Ibberson is a program manager at ABA where she works on ABA’s TCVS portal.
Full Article
CISA News: Agriculture Cybersecurity Workshop and Seminar
Wednesday, November 12, 2025
This workshop and seminar covering agriculture cybersecurity will be held on Wednesday, November 12, from 12:00-8:00 p.m. at McCrory Gardens Education and Visitor Center (631 22nd Ave., Brookings, SD 57006).
Location: McCrory Gardens | 631 22nd Ave, Brookings, SD 57007
Contact: Alexander "Sandy" Smart, Professor and SDSU Extension Interim Director
This workshop will highlight results from three collaborative research projects between South Dakota State University and Dakota State University. The workshop is open to faculty, graduate students and undergraduate students interested in learning more about agriculture cybersecurity as it relates to the implementation of precision agriculture.
Learn how data is secured as it is transferred from monitoring instruments to the cloud and how AI is used to detect crop anomalies for precision management. Andrew Rose, an advisor of BIO-ISAC, will present industry examples of agriculture cybersecurity issues and solutions to prevent data theft and ransom payments.
Agenda
- 12:00 p.m. - Welcome and Luncheon
- 1:00 p.m. - Research Reports from SDSU-DSU Ag Cybersecurity Team
- 3:00 p.m. - Break
- 3:30 p.m. - Ag Cybersecurity Workshop, led by Andrew Rose, BIO-ISAC
- 5:00 p.m. - Mixer and Networking (light dinner with refreshments)
- 7:00 p.m. - Public Seminar on Ag Cybersecurity, by Andrew Rose, BIO-ISAC
Registration
The cost to attend the workshop is $50. The public seminar, which begins at 7:00 p.m., is free to attend. Registration is required and can be completed HERE.

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2025 Succession Planning Online Workshop Series
November 3 & 17, 2025 | Online Zoom
This two-part workshop series is designed to help community banks establish a robust succession planning process. Participants will learn how to create a comprehensive succession plan, conduct talent assessments to identify skills gaps, and develop personalized development plans for their successors, focusing on leadership, management, and technical skills.
Part 1: Laying the Foundation – November 3, 2025 – 10 am – Noon CT
Part 2: Developing Your Successors – November 17, 2025 – 10 am – Noon CT
Key Takeaways: • You will gain a comprehensive understanding of how to establish a well-structured succession plan tailored for your community bank. • You will have the opportunity to develop a detailed succession plan for both current leadership and their potential successors. • You will receive practical tools and guidance to create personalized development plans for identified successors, focusing on leadership, management, and technical skills.
Details & Registration
2025 SDBA IRA Fall Update
November 20, 2025 | Sioux Falls
The IRA Update builds on the attendees’ knowledge of IRA basics to address some of the more complex IRA issues their financial organizations may handle. This course includes how the SECURE Act really changes our two biggest topics: RMDs and death distributions and discusses any pending legislation. This is a specialty session; some previous IRA knowledge is assumed. The instructor uses real-world exercises to help participants apply information to job-related situations.
Details & Registration
Online Education

Participating in learning opportunities outside the bank can be challenging. Take advantage of the SDBA's extensive selection of webinars and on-demand training to enhance your banking expertise directly from your computer.
GSB Online Seminars OnCourse Learning SBS Institute ABA Training
Question of the Week
Q: We have a customer who withdrew $15,000 from their account at a branch, but then another $500 from that same account via an out-of-network (foreign) ATM on the same business day. How should we file the CTR – and should we include the ATM transaction?
A: CTRs involving ATMs can often present some tricky considerations, and even those “BSA aficionados” out there may recognize the fact that the specific scenario outlined in the question above isn’t exactly addressed (nor settled) within direct industry guidance - and, as such, the filing “answer” may ultimately be subject to interpretation in the end.
There are effectively two relevant considerations that seemingly conflict in such cases - the first being the definition of an ATM within the CTR Filing Instructions themselves, paired with the fact that such transactions are typically reportable by the owners of those ATMs - and the other being the statutory requirement (and general reasoning behind a CTR) to report multiple currency transactions as one transaction if the bank "…has knowledge that they are by or on behalf of any person and result in either cash in or cash out totaling more than $10,000 during any one business day…”. Relatedly, for aggregation purposes, debits must be added to debits, and credits must be added to credits.
Here, though the ATM in question is non-proprietary, the $15K withdrawal triggered the CTR reportable threshold, and would be paired with the $500 withdrawal from the same account at the other bank-owned ATM for aggregation purposes just mentioned - so filing a CTR and including the ATM withdrawal may likely be appropriate under the language of both 31 CFR 1010.313(b) and the following from the CTR Filing Instructions:
"Multiple transactions must be treated as a single transaction if the financial institution has knowledge that they are by or on behalf of the same person and they result in either currency received (cash in) or currency disbursed (cash out) by the financial institution totaling more than $10,000 during any one business day. For a bank, a business day is the day on which transactions are routinely posted to customers’ accounts, as normally communicated to depository customers."
Essentially, if the bank is aware of both the branch $15,000 withdrawal and the $500 ATM withdrawal on the same business day (i.e., the withdrawal at the ATM would have posted on that same day, for instance), then it may be most appropriate that they both be included in the amount listed in Part I.
As with any BSA related query, the bank should also be sure to review its own BSA / AML, CIP, and CDD policies, procedures, and past practices as well, as ultimately, this may be more of a risk-based determination (and don’t forget to peruse our BSA / AML / OFAC Toolkit, for additional resources, as well).
Learn how to put compliance management solutions from Compliance Alliance to work for your bank, by contacting (888) 353-3933 or [email protected] and ask for our Membership Team. For timely compliance updates, subscribe to Bankers Alliance’s email newsletters.
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