To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week.
Federal Activities
State Activities
On June 27, the Office of the Comptroller of the Currency (OCC), alongside the Federal Deposit Insurance Corporation (FDIC) and the National Credit Union Administration (NCUA), with concurrence from the Financial Crimes Enforcement Network (FinCEN), issued an order granting an exemption from a specific requirement of the Customer Identification Program (CIP) Rule under § 326 of the USA PATRIOT Act. This exemption allows financial institutions to use alternative methods to collect Taxpayer Identification Number (TIN), (e.g., Social Security Number, individual taxpayer identification number, or employer identification number) information from third-party sources rather than directly from customers. The order applies to accounts at all entities supervised by the agencies. For more information, click here.
On June 27, the Consumer Financial Protection Bureau (CFPB) published a policy statement in the Federal Register outlining its approach to addressing criminally liable regulatory offenses. This publication comes in response to Executive Order 14294, issued by President Donald Trump on May 9, which aims to combat overcriminalization in federal regulations. The CFPB, responsible for administering and enforcing federal consumer financial laws, has issued regulations under statutes such as the Consumer Financial Protection Act, Truth in Lending Act, Real Estate Settlement Procedures Act, and Electronic Fund Transfers Act, some of which carry criminal penalties. The CFPB may refer alleged violations of criminal regulatory offenses to the Department of Justice. In making these referrals, the CFPB will consider factors such as the harm caused by the offense, potential gain to the defendant, the defendant’s specialized knowledge, and awareness of the unlawfulness of their conduct. For more information, click here.
On June 27, the U.S. District Court for the District of Oregon issued a significant ruling in the case of Wilson v. Hard Eight Nutrition LLC, marking the first decision since the U.S. Supreme Court’s ruling in McLaughlin Chiropractic Associates, Inc. v. McKesson Corporation. Plaintiff Wilson, representing a putative class, alleged that Hard Eight Nutrition LLC violated the Telephone Consumer Protection Act (TCPA) by sending unsolicited marketing text messages to his cell phone, which was registered on the Do-Not-Call Registry. The court denied the defendant’s motion to dismiss, affirming that a cell phone can be considered a “residential telephone” under the TCPA’s do-not-call provision, § 227(c). This decision aligns with the Federal Communications Commission’s (FCC) interpretation and the Ninth Circuit’s precedent, recognizing the evolving nature of telecommunication technologies and consumer privacy rights. The court also denied the defendant’s alternative motion to stay the case, as the Supreme Court’s recent decision in McLaughlin was already considered in the ruling. For more information, click here.
On June 26, the Federal Trade Commission (FTC) announced it is distributing more than $3.5 million in refunds to consumers affected by a fraudulent credit-repair scheme known as “The Credit Game.” This action follows a 2022 lawsuit against the scheme’s operators, Michael and Valerie Rando, who were accused of charging consumers exorbitant fees for ineffective credit-repair services, providing false information to credit-reporting agencies, and exploiting COVID-19 tax relief funds in violation of the COVID-19 Consumer Protection Act. The FTC’s legal action resulted in a court order halting the illegal operations and permanently banning the Randos from the credit-repair industry. As part of the settlement, the Randos were required to surrender assets to fund consumer refunds. The FTC is issuing checks and PayPal payments to 9,224 affected consumers, advising recipients to cash or redeem their payments promptly within the specified timeframes. For more information, click here.
On June 24, Senate Banking Chairman Tim Scott (R-SC), Subcommittee on Digital Assets Chair Cynthia Lummis (R-WY), Senator Thom Tillis (R-NC), and Senator Bill Hagerty (R-TN) released a set of guiding principles for the development of comprehensive market structure legislation for digital assets. These principles aim to provide a foundational framework for discussions and negotiations with industry participants, legal and academic experts, and government stakeholders. This announcement comes on the heels of the House Committees on Agriculture and Financial Services both favorably reporting to the House the CLARITY Act, which aims to establish a clear regulatory framework for digital assets in the U.S. and the recent passage by the U.S. Senate of the GENIUS Act, a landmark effort to establish a comprehensive federal framework for the payment stablecoins. For more information, click here.
On June 24, Politico issued a report indicating that House Republican leaders are considering a floor vote on landmark cryptocurrency legislation as early as the week of July 7. The proposed package includes new rules for dollar-pegged stablecoins and a broader crypto market structure bill, although no final decision has been made on whether to combine these efforts. The timing remains uncertain due to the GOP’s “Big Beautiful Bill,” which could delay the vote until later in the month. Trump has urged the House to adopt a “clean” version of the Senate-passed stablecoin legislation, which would establish the first U.S. regulatory framework for dollar-pegged digital tokens. However, House lawmakers may seek to reconcile this with their own stablecoin bill, which mirrors the Senate’s but includes key differences. Some Republicans aim to merge the stablecoin bill with the CLARITY Act, which allocates oversight of digital assets among market regulators. The CLARITY Act has already cleared relevant committees. Discussions are ongoing, with Majority Leader Steve Scalise expressing openness to combining the bills, a move favored by the crypto industry. For more information, click here.
On June 23, the CFPB released an updated report on the “credit invisibles” estimate, revealing significant revisions to previous data. The report, which corrects earlier methodological errors, indicates that the number of adults without a credit record in 2010 was overestimated, with the revised figure showing only 5.8% (13.5 million) as credit invisible, compared to the original 11% (25.9 million). This correction also led to an increase in the estimated share of adults with unscored credit records from 7.4% to 12.7%. By 2020, the share of credit invisibles had further decreased to 2.7% (7.0 million), while the proportion of adults with a scored credit record rose from 81.6% to 87.5% over the decade. This report underscores the evolving landscape of credit accessibility and the importance of accurate data in understanding consumer credit histories. For more information, click here.
On June 23, the Federal Reserve Board announced a significant policy change, stating that reputational risk will no longer be a component of examination programs in its supervision of banks. This decision initiates a process to review and remove references to reputation and reputational risk from supervisory materials, replacing them with more specific discussions of financial risk where appropriate. The board will ensure consistent implementation of this change by training examiners and collaborating with other federal bank regulatory agencies. Importantly, this modification does not alter the board’s expectation for banks to maintain robust risk management practices to ensure safety, soundness, and compliance with laws and regulations, nor does it affect how banks may choose to incorporate reputational risk into their own risk management strategies. For more information, click here.
On June 23, the U.S. House of Representatives passed the Deploying American Blockchains Act of 2025, a bipartisan initiative aimed at establishing the U.S. as a global leader in blockchain and distributed ledger technologies. Sponsored by Representatives Kat Cammack (R-FL) and Darren Soto (D-FL), the legislation mandates the Department of Commerce to create a comprehensive framework for the safe and responsible deployment of blockchain technology across the nation, thereby enhancing America’s innovation, cybersecurity, and economic competitiveness. The act establishes a Blockchain Deployment Program to coordinate federal efforts, foster public-private partnerships, and support innovation across key sectors, while ensuring the development of blockchain technologies aligns with American values of transparency, inclusion, and trust. For more information, click here.
On June 23, Senator Elizabeth Warren (D-MA) expressed serious concerns in a letter to key financial regulators, including Vice Chair Michelle Bowman of the Federal Reserve Board, Acting Comptroller Rodney Hood of the OCC, and Acting Chairman Travis Hill of the FDIC. The letter criticized reported plans to weaken the enhanced supplementary leverage ratio (eSLR), a crucial post-2008 financial crisis safeguard. Warren argued that reducing the eSLR, which requires banks to use at least $5 of their own money for every $95 of borrowed funds, would destabilize the financial system by allowing megabanks to prioritize shareholder payouts over financial stability. She emphasized that such deregulation could lead to increased financial risk, especially given the current economic challenges, and urged regulators to maintain strong capital requirements to protect the economy from potential crises. For more information, click here.
On June 20, the CFPB filed a statement of interest in support of converting the bankruptcy case of Synapse Financial Technologies, Inc. from Chapter 11 to Chapter 7, rather than dismissing it. This move comes amidst concerns over significant consumer harm stemming from Synapse’s alleged unfair practices in managing funds across its network of partner financial institutions. The shortfall between the money consumers had in their accounts at the time their accounts were frozen and the money that has been returned by the partner financial institutions may be as high as $95 million. If converted, the CFPB plans to continue its investigation into Synapse’s practices and pursue claims to address consumer harm. For more information, click here.
On June 30, the Illinois General Assembly sent the Digital Assets and Consumer Protection Act (SB1797) to the governor for approval. This comprehensive legislation aims to regulate digital asset business activities within the state, establishing a framework for registration, oversight, and consumer protection. It defines key terms such as “digital asset,” “covered person,” and “digital asset business activity,” and outlines the responsibilities of the Department of Financial and Professional Regulation in enforcing compliance. The act mandates registration for entities engaging in digital asset activities, sets forth requirements for customer disclosures, and imposes penalties for violations. It also establishes the Consumer Protection Fund to support the administration of the act. The legislation includes provisions for the protection of customer assets, examination and supervision of registrants, and cooperation with other regulatory agencies. The act is designed to ensure the integrity and security of digital asset transactions and safeguard consumer interests. For more information, click here.
On June 26, Rhode Island Governor Daniel McKee signed S 0169 into law, an act amending the state’s regulations on deceptive trade practices, specifically addressing credit reports and medical debt. The legislation clarifies the definition of “credit report” and excludes reports related to transactions between consumers and health care providers for medical debt. It also restricts the execution and attachment of a defendant’s principal residence and garnishment of wages for judgments based on medical debt, ensuring that such debts cannot lead to the seizure of a primary residence or wage garnishment. Additionally, the act prioritizes garnishments for child support over other claims. This law will take effect on January 1, 2026. For more information, click here.
On June 26, McKee signed S 0172 into law, an act addressing interest and usury regulations, specifically targeting medical debt. This legislation, introduced by a group of state senators, amends Chapter 6-26 of the General Laws to cap the interest rates on medical debt. The interest rate is tied to the weekly average one-year constant maturity Treasury yield, with a floor of 1.5% per annum and a ceiling of 4% per annum. Importantly, patients receiving financial assistance are exempt from any interest or late fees. The act applies only to new medical debt incurred after its effective date and took effect immediately upon passage. For more information, click here.
On June 24, McKee signed H 5811 into law, an act amending the state’s adoption of the Federal Secure and Fair Enforcement for Mortgage Licensing Act of 2009. This legislation aims to enhance consumer protection by outlining prohibited acts and practices for individuals and entities involved in mortgage lending. Key provisions include prohibitions against fraudulent schemes, deceptive practices, and misrepresentation in mortgage transactions. The act also mandates proper licensing for conducting mortgage-related business and requires full compliance with both state and federal regulations. Additionally, it restricts dual compensation in real estate and mortgage transactions and ensures truthful financial disclosures to protect borrowers. The law took effect immediately upon passage. For more information, click here.
On June 23, the New York State Department of Financial Services issued guidance to all entities under its regulation, emphasizing the critical importance of adhering to U.S. sanctions and complying with New York state and federal laws, particularly in light of ongoing global conflicts. The guidance underscores the heightened risk of cybersecurity threats, including ransomware and phishing attacks, urging regulated entities to review and enhance their cybersecurity measures in accordance with 23 NYCRR Part 500. It also highlights the necessity for vigilant compliance with sanctions, especially concerning virtual currency transactions, to prevent evasion by sanctioned individuals and entities. The department advises entities to stay updated with communications from relevant federal agencies and to ensure their systems and processes are aligned with the latest regulatory requirements. For more information, click here.
On June 23, McKee signed H 5121 into law, an act that introduces comprehensive regulations for virtual currency kiosk operators, mandating licensing and registration requirements, and setting forth detailed disclosure obligations to protect consumers. It also imposes daily transaction limits for new and existing customers and requires the use of blockchain analytics software to prevent fraudulent activities. Additionally, the law mandates that virtual currency kiosk operators provide live customer service during specified hours and outlines the responsibilities of compliance officers to ensure adherence to both state and federal regulations. For more information, click here.
On June 23, Connecticut Governor Ned Lamont signed Substitute House Bill No. 6990 into law, which addresses the seizure and forfeiture of virtual currency and virtual currency wallets. Effective July 1, 2026, this legislation allows for the forfeiture of virtual currency and wallets used in or derived from certain criminal activities, as specified in the general statutes. The act establishes a legal framework for the state to petition for forfeiture through civil proceedings, requiring clear and convincing evidence. It ensures that property used for legitimate attorney’s fees is exempt from forfeiture and mandates that forfeited assets be used to compensate victims of the related crimes. The law also clarifies that virtual currency kiosks are not subject to seizure or forfeiture under this act. For more information, click here.
On June 23, state privacy enforcement authorities in California, Connecticut, Delaware, New Jersey, Oregon, and Vermont sent a letter to U.S. Senate Majority Leader John Thune and Minority Leader Charles E. Schumer expressing their opposition to the proposed AI Enforcement Moratorium included in the Budget Reconciliation Bill. The moratorium seeks to prevent states from enforcing AI-related laws for a decade, which the state authorities argue would undermine state autonomy and strip millions of Americans of existing privacy rights. Highlighting the states’ historical leadership in privacy protection, such as California’s pioneering data breach notification and consumer privacy laws, the letter emphasizes the importance of state-level innovation and responsiveness to emerging privacy threats posed by AI technologies. The state authorities urge the Senate to reject the moratorium, advocating for the preservation of states’ ability to safeguard privacy rights amidst rapidly evolving technological challenges. For more information, click here.
On June 20, the Texas Legislature passed H.B. 700, which introduces several new regulatory requirements for providers and brokers of commercial sales-based financing operating within the state. The law applies to merchant cash advance transactions and loans with payments that vary based on the borrower’s sales. Most significantly, the new law prohibits the establishment of automatic debit mechanisms from a merchant’s deposit account unless the finance company holds a validly perfected security interest in the account. This requirement poses a substantial operational challenge, because obtaining a security interest in a deposit account requires a control agreement with the merchant and the merchant’s bank. The law also mandates consumer-like disclosures for commercial sales-based financing transactions, including disclosure of the total financing amount, finance charge, total repayment amount, estimated term, payment schedule, collateral requirements, additional fees, certain prepayment terms, and whether the provider pays compensation to a broker. The law does not require an APR disclosure. The law also requires providers and brokers to register with the Office of Consumer Credit Commissioner. For more information, click here.
On June 20, Texas Governor Greg Abbott signed S.B. No. 1644 into law, a legislative measure impacting the use of consumer credit scores in underwriting or rating personal lines property and casualty insurance policies. This act mandates insurers to provide written or electronic notice to applicants or insured individuals if adverse actions are taken based on credit report information. It also requires insurers to use credit reports issued within 90 days for policy issuance or renewal and to update credit reports every 36 months, adjusting premiums accordingly. Insurers must re-underwrite and re-rate policies upon request once every 12 months, based on current credit reports. The act, effective September 1, applies to policies delivered or renewed on or after January 1, 2026, ensuring transparency and fairness in insurance underwriting practices. For more information, click here.
On June 20, Texas Governor Greg Abbott signed HB 1314 into law, an act concerning price estimates and billing requirements for certain health care facilities. This legislation mandates that health care facilities provide consumers with written estimates of expected billed charges for nonemergency elective medical services or procedures upon request, prior to scheduling. The act requires facilities to deliver these estimates via email within five business days and includes provisions for consumers to dispute final charges exceeding the estimate by $400 or more. Additionally, the act prohibits facilities from engaging in third-party collection actions, reporting to credit bureaus, or pursuing legal action against consumers for violations of these requirements. The law, effective September 1, repeals Subchapter B, Chapter 324, Health and Safety Code, and applies only to estimate requests made on or after its effective date. For more information, click here.
On June 17, Oregon Governor Tina Kotek signed Senate Bill 605 into law. This legislation amends ORS 646.608 and 646A.677, focusing on the reporting and collection of medical debt. The bill mandates that hospitals and nonprofit hospital-affiliated clinics post their financial assistance policies and conduct screenings to determine patient eligibility for financial aid or state medical assistance before transferring unpaid charges to debt collectors. It also prohibits the reporting of medical debt to consumer reporting agencies and restricts the interest rates that can be charged on medical debts. Violations of these provisions are deemed unlawful practices under Oregon law, with potential for the court to declare such debts void and uncollectible. For more information, click here.
