Law360: Compliance Changes On Deck For Banks Under Texas AI Law

On June 2, the Texas state Legislature passed H.B. 149, the Texas Responsible Artificial Intelligence Governance Act, or TRAIGA. Texas Gov. Greg Abbott signed the bill into law on June 22, and it takes effect Jan. 1, 2026.

Without AI-focused federal legislation or a federal moratorium on state AI laws, Texas now positions itself alongside Colorado as a testing ground for safe and transparent use of AI systems and includes an enforcement mechanism that penalizes improper AI use that could potentially harm state residents.

Check out the full Law360 article HERE and download a copy HERE.

About the Authors

Chris Napier is a Partner at Mitchell Sandler. His practice focuses on providing regulatory counseling, strategic advice and representation during government enforcement matters, including matters involving commercial, consumer and alternative credit products; money transmission and payments; deposit issues; and partnerships between fintech companies, depository institutions, and lenders.

Chloé Dolsenhe is Senior Associate at Mitchell Sandler. She specializes in regulatory compliance, government enforcement, and internal investigations primarily for financial technology companies, depository institutions and third-party service providers. She brings her experience as a government enforcement attorney where she leveraged AI in investigations and led the Generative AI Working Group in the Enforcement Division of the Office of the Comptroller of the Currency.  She advises clients seeking compliance guidance when integrating artificial intelligence and integrating digital assets into their consumer products.  

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