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On January 14, the NCUA issued a letter outlining its supervisory priorities and examination program updates for 2026. The letter emphasizes risk-focused supervision, continued reliance on defined-scope examinations for smaller institutions, and adherence to a “no regulation by enforcement” approach, while reaffirming that examiners will continue enforcing all applicable consumer protection and safety and soundness requirements.

Continue Reading NCUA Issues 2026 Supervisory Priorities Letter Emphasizing Safety, Soundness, and Risk-Focused Examinations

On January 5, New York City Mayor Zohran Mamdani issued two executive orders aimed at increasing scrutiny of pricing practices that the City views as contributing to affordability concerns. Executive Order 9 addresses certain add-on or post purchase charges commonly referred to as “junk fees,” while Executive Order 10 targets subscription enrollment and cancellation practices described by City officials as “subscription tricks and traps.”

Continue Reading New York City Targets “Junk Fees” and Subscription Practices Through New Executive Orders

On December 30, Baltimore Mayor Brandon M. Scott announced that the City of Baltimore filed a civil action against a fintech provider offering small-dollar cash advance products, alleging violations of the Baltimore Consumer Protection Ordinance. According to the City, the fintech’s cash-advance product that was promoted as an earned wage access or overdraft-style service but allegedly imposed costs that far exceeded Maryland’s 33 percent interest-rate cap for consumer loans.

Continue Reading Baltimore Sues Fintech for Alleged Unfair and Deceptive Cash-Advance Practices

On December 2, a non-governmental policy organization affiliated with Democratic state attorneys general announced the formation of a Consumer Protection and Affordability Working Group. The initiative will be supported by participating attorneys general and advised by Rohit Chopra, the former Director of the Consumer Financial Protection Bureau and former Commissioner at the Federal Trade Commission.

Continue Reading Former CFPB Director to Lead New Consumer Protection and Affordability Initiative

On November 21, the CFPB announced changes to how its Supervision Division will conduct examinations, including a new “Humility Pledge” that examiners must read to supervised entities at the start of each review. The Bureau stated that the updated approach reflects its commitment to operating within its statutory authority and aligns with the Memorandum on Supervision and Enforcement Priorities issued in April 2025 (previously discussed here).

Continue Reading CFPB Signals Major Shift in Exam Approach With New “Humility Pledge”

On November 5, the Washington Department of Financial Institutions issued a consent order against a mortgage company and its designated broker following an examination of activities under the Mortgage Broker Practices Act and the Consumer Loan Act. The order resolves allegations that the company failed to comply with various state and federal requirements governing mortgage origination and advertising.

Continue Reading Washington DFI Finalizes $60,000 Consent Order Addressing Alleged Advertising, Disclosure, and Reporting Failures

On October 27, 2025, amendments to Delaware’s Medical Debt Protection Act took effect, establishing a total ban on the inclusion of medical debt in consumer credit reports. The amendments, enacted through Senate Substitute 1 for Senate Bill 156, revise Delaware’s consumer protection laws to prohibit both the furnishing and use of medical-debt information by consumer reporting agencies.

Continue Reading Delaware Bans Medical Debt from Consumer Credit Reports

On November 3, the U.S. District Court for the Northern District of West Virginia granted class certification certified a statewide class of borrowers challenging a credit union’s alleged assessment of unauthorized “pay-to-pay” fees under the West Virginia Consumer Credit and Protection Act. The plaintiff alleged that the institution imposed a 5 dollar fee each time consumers made monthly payments by phone or other electronic means, even though neither the loan agreement nor any statute authorized the charge.

Continue Reading West Virginia Federal Court Certifies Class Action Challenging “Pay-to-Pay” Fees

On October 28, the CFPB issued an interpretive rule under the Fair Credit Reporting Act (FCRA) declaring that federal law generally preempts state laws governing the content of consumer credit reports. The Bureau’s action, led by Acting Director Russell Vought, replaces and withdraws a July 2022 interpretive rule issued under the prior administration, which had concluded that the FCRA’s preemption provisions were limited in scope.

Continue Reading CFPB Issues Interpretive Rule Asserting Federal Preemption Over State Medical Debt Credit Reporting Laws

On October 7, the U.S. District Court for the Northern District of California denied a fintech company’s motion to compel arbitration in a putative class action. The plaintiffs, both servicemembers, allege that the company’s earned wage access (EWA) product violates the Military Lending Act (MLA), the Truth in Lending Act (TILA), and the Georgia Payday Lending Act (GPLA).

Continue Reading District Court Denies Arbitration of Service Members’ Class Action Claims Under Military Lending Act Holding That Earned Wage Access Constitutes Extension of Consumer Credit

On October 14, the Maryland Office of Financial Regulation (OFR) issued regulatory guidance explaining three new state laws governing the collection and reporting of medical debt. The guidance clarifies how House Bills 428, 1020, and 268, all effective October 1, 2025, alter the obligations of hospitals, debt collectors, and consumer reporting agencies.

Continue Reading Maryland OFR Issues Guidance on New Medical Debt Collection Laws