Enforcement

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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 8, the Oregon Department of Consumer and Business Services entered into a consent order with two affiliated companies resolving allegations of violations of the Oregon Consumer Finance Act arising from a bank partnership program. According to the regulator, the companies allegedly charged, contracted for, or received interest above Oregon’s statutory limits on hundreds of consumer loans made to Oregon residents, even though the loans were originated and funded by an out-of-state, state-chartered bank.Continue Reading Oregon Enters $1.56 Million Consent Order Over Alleged Excessive Interest Charges in Bank Partnership Lending Program

On December 9, FinCEN announced a consent order imposing a $3.5 million civil money penalty on a peer-to-peer virtual asset trading platform, alleging willful violations of the Bank Secrecy Act. FinCEN alleged that the platform’s compliance failures allowed it to process substantial volumes of transactions connected to criminal activity, sanctions exposure, and other high-risk conduct over an extended period.Continue Reading FinCEN Assesses $3.5 Million Penalty Against Virtual Asset Platform for Alleged BSA Violations

On November 25, the Washington Department of Financial Institutions (DFI) issued a Temporary Order to Cease and Desist and a Statement of Charges against a virtual-currency kiosk operator, alleging violations of the Uniform Money Services Act arising from its Washington money-transmission activities. The agency alleges that the company engaged in unsafe and unsound practices and failed to safeguard customer funds.Continue Reading Washington DFI Seeks License Revocation and Industry Ban After Alleged Uniform Money Services Act Violations

On November 20, 2025, the CFPB notified staff that it will begin transferring its remaining enforcement lawsuits and other pending litigation to the Department of Justice. The shift comes as the agency anticipates running out of operating funds under the Consumer Financial Protection Act (previously discussed here). Continue Reading CFPB to Begin Transferring Remaining Litigation to DOJ Amid Funding Collapse

On November 17, the FTC announced a final court order permanently banning a small-business financing company and its chief executive from offering business financing, debt relief, and credit repair services and imposing a $48,280,328 monetary judgment to resolve allegations of unfair or deceptive acts or practices under the Federal Trade Commission Act, and violations of the Telemarketing Sales Rule and the Consumer Review Fairness Act. The order follows a summary-judgment ruling entered on September 16. The FTC filed a complaint against the company in November 2024.Continue Reading FTC Permanently Bans Small-Business Financing Firm and CEO for Alleged UDAP and Telemarketing Violations

On November 3, 2025, the Consumer Financial Protection Bureau terminated its 2023 consent order against a national consumer reporting agency. The original order, issued in October 2023, required more than three million dollars in consumer redress and a five million dollar civil money penalty and addressed alleged violations of the Consumer Financial Protection Act, the Fair Credit Reporting Act, and the Economic Growth, Regulatory Relief, and Consumer Protection Act.Continue Reading CFPB Terminates 2023 Consent Order Against a National Consumer Reporting Agency for Alleged Security Freeze Violations

On October 30, the California DFPI entered a consent order with a residential mortgage lender and servicer following a regulatory examination and a directed self-audit. The DFPI alleged violations of the California Residential Mortgage Lending Act and California Civil Code provisions governing when per diem interest may begin to accrue.Continue Reading DFPI Orders Mortgage Lender to Pay $100,000 for Alleged Per Diem Interest and Recordkeeping Violations

On October 30, the Pennsylvania Office of Attorney General announced a $750,000 settlement with a collectibles company resolving allegations that the business used deceptive “negative option” subscription features in violation of the Pennsylvania Unfair Trade Practices and Consumer Protection Law. The settlement follows more than 200 consumer complaints concerning automatic enrollments, hidden charges, and aggressive collection activity.Continue Reading Pennsylvania Attorney General Secures $750,000 Settlement Over “Negative Option” Collectibles Sales

On October 17, 2025, the California Department of Financial Protection and Innovation (DFPI) entered a consent order with a licensed consumer lender, alleging violations of the Fair Access to Credit Act, which amended the California Financing Law to cap interest rates and fees on consumer loans between $2,500 and $10,000. The DFPI alleged that the lender charged rates and administrative fees above those limits and continued the practice as recently as January 2023.Continue Reading DFPI Orders Lender to Pay $1 Million for Alleged Violations of the Fair Access to Credit Act

On October 16, the OCC announced a formal agreement with a national bank in Florida for alleged unsafe or unsound practices related to board oversight, corporate governance, strategic and capital planning, and compliance with the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) requirements. The OCC also alleged violations involving the Suspicious Activity Reports rule under the Bank Secrecy Act and the due diligence program requirements for correspondent accounts for foreign financial institutions under the USA PATRIOT Act.Continue Reading OCC Settles with Bank Over Alleged BSA/AML Violations