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Mehul Madia

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Mehul Madia, special counsel in the firm's Washington, D.C. office, provides deep consumer finance and fintech expertise to clients, leveraging more than 15 years’ of public and private sector experience.

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On July 9, the New York Department of Financial Services (NYDFS), joined by regulators from five other states, entered into a multistate settlement with a money transmitter headquartered in New York. The $4.2 million consent order resolves allegations arising from a multistate examination conducted by the Conference of State Bank Supervisors (CSBS) and the Money Transmitter Regulators Association (MTRA) citing alleged violations of the Bank Secrecy Act (BSA), FinCEN regulations, and the CFPB’s Remittance Transfer Rule.Continue Reading NYDFS and Other State Regulators Impose $4.2 Million Penalty on Money Transmitter

On June 26, Rhode Island Governor Dan McKee signed companion bills S 0169 and S 0172 into law, twin measures that amend the state’s Deceptive Trade Practices Act and Interest and Usury statute to impose some of the nation’s strictest limits on the reporting and collection of medical debt. S0169 becomes effective January 1, 2026, while S0172 took effect immediately upon passage.Continue Reading Rhode Island Enacts Ban on Reporting Medical Debt to Credit Bureaus

On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the FTC’s “click-to-cancel” Negative Option Rule, holding that the FTC violated the FTC Act and the Administrative Procedure Act when it finalized the rule (previously discussed here). The court found that the FTC wrongly determined that the economic effect of the proposed rule would be under $100 million, and accordingly declined to conduct a preliminary regulatory analysis that would have identified alternative approaches. The failure to do this analysis deprived businesses the opportunity for participation in the rulemaking process. Because that procedural error affected the rule as a whole—including the requirement that cancellation mechanisms be as simple as enrollment—the court vacated the rule in its entirety. Although the rule included a severability clause, the court found that partial enforcement was not feasible given the scope of the defect and the prejudice to petitioners.Continue Reading Eighth Circuit Vacates FTC’s “Click-to-Cancel” Negative Option Rule

On June 25, the California DFPI announced that it had finalized a consent order with a cryptocurrency kiosk operator, alleging violations of the Digital Financial Assets Law (DFAL) and the California Consumer Financial Protection Law (CCFPL). The action marks the DFPI’s first enforcement under the DFAL, which took effect on January 1, 2024.Continue Reading DFPI Finalizes $300,000 Settlement with Crypto Kiosk Operator for Alleged Digital Asset Law Violations

On July 4, the “One Big Beautiful Bill Act,” was signed into law, which includes a provision to reduce the cap on the CFPB’s annual funding. The bill lowers the cap from 12% to 6.5% of the Federal Reserve’s total operating expenses for the fiscal year 2009, adjusted each year for inflation.Continue Reading CFPB Funding Cut Nearly 50% by “One Big Beautiful Bill Act”

On July 1, the CFPB terminated two separate consent orders, one involving a federal credit union and the other involving a national mortgage servicer. Both orders stemmed from 2024 enforcement actions and involved alleged violations of the Consumer Financial Protection Act (CFPA), with the mortgage servicing matter also receiving violations of the Real Estate Settlement Procedures Act, the Truth in Lending Act, and the Homeowners Protection Act. Continue Reading CFPB Terminates Two Consent Orders Addressing Overdraft Fees and Mortgage Servicing Violations

On June 24, the Department of Housing and Urban Development (HUD) issued a Request for Information (RFI) to evaluate how Buy Now Pay Later (BNPL) loans may affect FHA-insured mortgage underwriting. The RFI seeks comment on whether short-term, unsecured BNPL debt may distort borrowers’ debt-to-income calculations and undermine housing affordability. Comments are due by August 25, 2025.Continue Reading HUD Requests Public Input on Buy Now Pay Later Loans and FHA Mortgage Eligibility

On June 20, Texas Governor Greg Abbot signed into law HB 700, adding Chapter 398 to the Texas Finance Code. Effective September 1, the statute establishes a regulatory framework for commercial sales-based financing and imposes specific compliance obligations on providers offering such products to Texas borrowers. Continue Reading Texas Passes Legislation to Regulate Sales-Based Financing

On June 22, 2025, Texas Governor Greg Abbott signed into law House Bill 149, enacting the Texas Responsible Artificial Intelligence Governance Act (TRAIGA). The law establishes one of the nation’s most comprehensive state-level artificial intelligence regulatory frameworks. TRAIGA imposes disclosure, consent, and compliance requirements on developers, deployers, and governmental entities who use artificial intelligence systems (AI). The law is set to take effect on January 1, 2026.Continue Reading Texas Enacts Sweeping AI Law: Disclosure, Consent, and Compliance Requirements Take Effect in 2026

On June 27, Pennsylvania enacted Senate Bill 202, which significantly expands the Commonwealth’s Money Transmitter Act (MTA) to include virtual currency transmission. Under the amended law, transmitting virtual currency is regulated in the same manner as traditional money transmission, which includes the obtainment of a license. The law will take effect 60 days from enactment.Continue Reading Pennsylvania to Require Licenses for Virtual Currency Transmitters

On June 25, the Federal Housing Finance Agency (FHFA) issued a directive ordering Fannie Mae and Freddie Mac to prepare proposals for treating cryptocurrency held on U.S.-regulated exchanges as assets for reserves in single-family mortgage loan risk assessments without requiring conversion to U.S. dollars.Continue Reading FHFA Orders Fannie Mae and Freddie Mac to Consider Cryptocurrency Reserves in Mortgage Risk Assessments