Banks don't know if they should be running disparate impact analysis or not. The CFPB is rewriting its own rules. State AGs are filling the gaps. And the legal questions around agentic AI haven't even been answered yet. CBA General Counsel David Pommerehn breaks down what's actually happening and what lending leaders should do about it.

Recorded at CBA Live 2026 in San Diego, this episode covers:
- The CFPB under the current administration
- Reg B and the elimination of disparate impact
- State AGs stepping in where federal enforcement pulls back
- Agentic AI and the legal ramifications under Reg E
- Section 1033 and the data portability rewrite
- Data sharing versus data security
- Fraud and scams as a whole government problem
- Why UDAP reform matters more than you think

If you are navigating compliance strategy or staffing for the back half of 2026, this conversation matters.

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Chapters:
00:00 Top legal and regulatory risks for bank leaders
01:12 How the CFPB has changed under the current administration
03:48 Reg B and the elimination of disparate impact
05:49 State AGs stepping in where the CFPB pulls back
09:54 Agentic AI and the legal questions nobody's answered yet
11:03 Section 1033, data portability, and the rewrite
14:10 Navigating data sharing vs. data security
16:13 What's actually working in fraud prevention
19:04 The regulation assumption David has changed his mind on
20:54 Why UDAP reform matters more than you think

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