News & Analysis as of

Consent Order Enforcement Actions

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Used Oil Enforcement: Alabama Department of Environmental Management and Montgomery Waste Transportation Company...

The Alabama Department of Environmental Management (“ADEM”) and Sun Coast Resources, LLC (“SCR”) entered into an August 7th Consent Order (“CO”) addressing the violation of certain Alabama regulations concerning...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Brewton Railcar Repair Facility Enter into Consent...

The Alabama Department of Environmental Management (“ADEM”) and Frit Car, Inc. (“FCI”) entered into an August 6th Consent Order (“CO”) addressing alleged violations of the Alabama Hazardous Waste Regulations. See Consent...more

Parker Poe Adams & Bernstein LLP

Federal Trade Commission Finalizes Order With Web Hosting Company Over Data Security Failures

On May 21, 2025, the Federal Trade Commission (FTC) finalized a consent order with GoDaddy to settle allegations that the web hosting company misled customers and failed to implement basic data security protections. Although...more

Hudson Cook, LLP

Online Dating Service Agrees to Pay $14 Million to Resolve FTC Lawsuit

Hudson Cook, LLP on

On August 12, 2025, the Federal Trade Commission announced that a large online dating company (the "Company") agreed to stop alleged unlawful practices related to advertising, cancellation, and billing. ...more

Morrison & Foerster LLP

NYDFS Settles with Stablecoin Issuer for Alleged Compliance Failures

Last week, New York State Department of Financial Services (NYDFS) left no doubt that it will continue to actively regulate cryptocurrency despite the pullback in law enforcement efforts by the federal government, including...more

Foley & Lardner LLP

Health Care Marketing Enforcement: FTC Targets Telehealth Company for Deceptive Weight Loss Marketing Claims

Foley & Lardner LLP on

On July 14, 2025, the operators of telemedicine company Southern Health Solutions, Inc., doing business as Next Medical and NextMed, agreed to settle the Federal Trade Commission’s (FTC) charges that the company’s weight‑loss...more

Sheppard Mullin Richter & Hampton LLP

Federal Court Rejects DOJ’s Request to End Oversight of Pennsylvania Bank’s Redlining Settlement

On July 23, the U.S. District Court for the Eastern District of Pennsylvania denied the Department of Justice’s motion to terminate a consent order requiring a Pennsylvania bank to implement a five-year fair lending...more

Goodwin

CFPB Terminates Consent Order Against Credit Union

Goodwin on

On July 21, 2025, the Consumer Financial Protection Bureau (CFPB) announced that it had terminated its October 2024 consent order with a Florida-based credit union....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Stormwater Enforcement: Alabama Department of Environmental Management and St. Clair County Developer Enter into Consent Order

The Alabama Department of Environmental Management (“ADEM”) and Raughton Holdings LLC (“RH”) entered into a July 7th Consent Order (“CO”) addressing violations of the ADEM Clean Water Act National Pollution Discharge...more

Sheppard Mullin Richter & Hampton LLP

CFPB Terminates Consent Order Against Credit Union Early

On July 18, the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS ACT) was signed into law, creating the first federal regulatory framework for payment stablecoins. The law prohibits the issuance...more

Lathrop GPM

Understanding the Proposed IRS Settlement Regarding the Johnson Amendment and Churches’ Political Speech Rights

Lathrop GPM on

To settle a case challenging the Johnson Amendment, the IRS has proposed to allow at least two churches to endorse candidates from the pulpit. This proposal has received widespread attention, but many questions remain...more

Troutman Pepper Locke

California’s DFPI Brings First Enforcement Action Under California’s Digital Financial Assets Law

Troutman Pepper Locke on

On June 25, the California Department of Financial Protection and Innovation (DFPI) entered a consent order with Coinme, Inc., a cryptocurrency “ATM” operator, for noncompliance with the California’s Consumer Financial...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Calhoun County Metal Plating Facility Enter into...

The Alabama Department of Environmental Management (“ADEM”) and Industrial Plating CO., Inc. (“IP”) entered into July 9th Consent Order (“CO”) addressing alleged violations of the Alabama Hazardous Waste Regulations. See...more

Vinson & Elkins LLP

Prior Approval Remedies in M&A: Agency Policy and Practice

Vinson & Elkins LLP on

For twenty-five years prior to the Biden Administration, FTC and DOJ consent agreements have had a singular goal: to remedy the anticompetitive effects of proposed transactions. Under former Chair Khan, however, the FTC...more

Troutman Pepper Locke

First Enforcement Action Taken by California’s Department of Financial Protection and Innovation Under DFAL

Troutman Pepper Locke on

Recently, the Department of Financial Protection and Innovation (DFPI) in California issued a consent order against Coinme Inc., a company operating digital financial asset kiosks, commonly known as Bitcoin ATMs, across the...more

Sheppard Mullin Richter & Hampton LLP

DFPI Finalizes $300,000 Settlement with Crypto Kiosk Operator for Alleged Digital Asset Law Violations

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...more

Sheppard Mullin Richter & Hampton LLP

CFPB Terminates Two Consent Orders Addressing Overdraft Fees and Mortgage Servicing Violations

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...more

Orrick, Herrington & Sutcliffe LLP

CFPB terminates consent order against mortgage servicer

On July 1, the CFPB announced that it terminated a consent order against a mortgage servicer after finding that the company had “fulfilled several obligations,” including payment of a $2 million civil money penalty and $3...more

Orrick, Herrington & Sutcliffe LLP

CFPB cancels consent order with a federal credit union

On July 1, the CFPB terminated a consent order with a federal credit union by issuing an order terminating the consent order. The original consent order was issued on November 7, 2024, concerning alleged violations of...more

Orrick, Herrington & Sutcliffe LLP

DFPI settles with crypto kiosk operator for $350K+

On June 25, the California DFPI announced it had entered into a consent order with a crypto kiosk operator for violations of the Digital Financial Assets Law (DFAL). Under the consent order, the operator agreed to pay a...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Wastewater Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and City of Atkins Enter...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“DEQ”) and City of Atkins, Arkansas entered into a May 15th Consent Administrative Order (“CAO”) addressing alleged violations of a Clean...more

Orrick, Herrington & Sutcliffe LLP

FTC requires company to pay $10M for alleged UDAP violations related to money transmission

On June 20, the U.S. District Court for the Northern District of Illinois entered a stipulated order for injunction and monetary judgment, requiring a retail corporation, which provides financial services, to pay $10 million...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Stormwater Enforcement: Mississippi Commission on Environmental Quality and Meridian Sand/Clay Mine Operator Enter into Agreed...

The Mississippi Commission on Environmental Quality (“MCEQ”) and Cullum Construction, LLC (“CC”) entered into a June 25th Agreed Order (“AO”) addressing alleged violations of a Clean Water Act Stormwater Permit. See Order No....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Malvern Brick Manufacturing...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“DEQ”) and Acme Brick Company (“ABC”) entered into a Consent Administrative Order (“CAO”) addressing an alleged violation of an Air...more

Sheppard Mullin Richter & Hampton LLP

OCC Enters Consent Orders Against New York-based Bank

On May 14, the OCC entered into a formal agreement with a New York-based bank after determining that the institution is in “troubled condition.” In its findings, the OCC cited alleged unsafe or unsound practices tied to the...more

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