Continue Reading Maryland Finalizes Comprehensive Rules Governing Virtual Currency Kiosks
Timely Insights and Updates at the Intersection of Financial Services, Fintech, and Consumer Protection
On January 7, the NYDFS finalized a rule amending its banking regulations to implement New York’s state Community Reinvestment Act requirements for certain nonbank mortgage lenders. The rule requires DFS to review how covered mortgage bankers serve the credit needs of their communities.Continue Reading New York Finalizes CRA-Style “Equitable Access” Rules for Mortgage Bankers
On December 19, New York Governor Kathy Hochul signed into law S8416, amending New York’s General Business Law to enact the Fostering Affordability and Integrity Through Reasonable Business Practices Act. The law expands the state’s primary consumer protection statute beyond deceptive acts to also prohibit unfair and abusive business practices.Continue Reading New York Enacts FAIR Business Practices Act Expanding State Consumer Protection Law
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 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 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 18, the California Privacy Protection Agency (CPPA) announced the creation of a Data Broker Enforcement Strike Force within its Enforcement Division to investigate alleged violations of the California Consumer Privacy Act and the Delete Act’s data broker registration requirements. The Agency stated that the new unit will expand its review of the data broker industry and support implementation of the Delete Request and Opt-Out Platform, which will allow consumers to submit a single deletion request to all registered data brokers beginning in January 2026.Continue Reading California’s Privacy Protection Agency Creates Data Broker Enforcement Strike Force
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 31, the Ohio Division of Financial Institutions (DFI) issued updated Bank Partnership Guidance under the state’s Small Loan Act, reversing its earlier position from December 2024 and January 2025. The DFI had previously advised that any nonbank entity arranging consumer loans of $5,000 or less in exchange for compensation, including loans originated by federally insured banks, would be required to obtain a state license. The latest guidance withdraws that interpretation and pauses licensing and enforcement for the near term.Continue Reading Ohio DFI Withdraws Prior Interpretation, Suspends Licensing for Bank Loan Arrangers Under Small Loan Act
On November 5, 2025, a national debt collection trade group and one of its members filed a lawsuit against the state of Colorado’s in an attempt to block its 2023 medical debt credit reporting law, HB 23-1126. The complaint alleges that the law, which bars adverse medical debt information from consumer credit reports and restricts related collection communications, is preempted by the Fair Credit Reporting Act and violates the First Amendment.Continue Reading Colorado’s Medical Debt Reporting Law Challenged in Federal Court
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
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