On March 25, President Trump signed an Executive Order requiring federal agencies to stop issuing paper checks for most disbursements by September 30. Exec. Order No. 14,247, 90 Fed. Reg. 14001 (Mar. 25, 2025). To combat what the Executive Order describes as the “risks of fraud, lost payments, thefts, and inefficiencies” associated with paper checks, all executive departments and agencies will be required to transition to electronic funds transfer (EFT) methods, such as direct deposit or credit card payments. This move will bring the vast majority of federal disbursements under Reg E’s purview, as Reg E governs most EFTs initiated to or from a consumer’s personal accounts.

Since taking office, the Trump administration has significantly curtailed the CFPB’s rulemaking and enforcement activity. Recently, Congress and federal courts have been grappling with what that means for CFPB employees and the rules the CFPB has enacted and enforces. On April 9, 2025, the United States House of Representatives voted to pass a joint resolution disapproving a CFPB rule that would make certain large payment companies subject to Regulations E and Z. The same day, the Court of Appeals for the D.C. Circuit heard oral arguments to resolve a TRO that would maintain the existence of the CFPB as it stood before the administration change. What does this mean for you and your clients? 

Cybersecurity requirements for contractors doing business with the U.S. federal government are nothing new.