On May 17, 2022, the Federal Deposit Insurance Corporation (“FDIC”) promulgated a final rule implementing its statutory authority to prohibit persons from making misrepresentations about FDIC insurance or misusing the FDIC’s name or logo (the “Final Rule”). On the same day, and in support of the Final Rule, the Consumer Financial Protection Bureau (“CFPB”) released an enforcement circular explaining to other agencies responsible for enforcing federal consumer financial law that such misrepresentations or misuse also likely violates the Consumer Financial Protection Act’s (“CFPA”) prohibition on deception. The circular marks the first issuance in furtherance of the CFPB’s May 16, 2022 announcement of a “new system” to provide guidance to other agencies on how the CFPB intends to enforce federal consumer financial law. In connection with the Final Rule and the circular, Rohit Chopra, the CFPB’s Director and a voting member of the FDIC’s Board of Directors, issued a statement highlighting the CFPB’s particular concerns “about potential misconduct involving novel technologies, including so-called stablecoins and other crypto-assets.” While acknowledging the potential benefits these new technologies can present, Director Chopra warned they “nonetheless pose risks to consumers who may be baited by misrepresentations or false advertisements about deposit insurance.”