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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....more
Yesterday, the New York City Department of Consumer and Worker Protection (NYC DCWP) announced another delay in the effective date of its amended debt collection rules. This marks the second postponement. As discussed here,...more
On July 14, the Consumer Financial Protection Bureau (CFPB or Bureau) filed a status report announcing its decision not to reissue its Medical Debt Collection Advisory Opinion, which had been issued in 2024 to “remind debt...more
In our Consumer Finance Compass series, Balch’s Jason Tompkins offers a preview of his upcoming presentation for the Association of Credit & Collection Professionals (ACA) Convention 2025, titled “Class Action Lawsuits in...more
A Texas federal judge has voided a Biden Administration CFPB rule that would have prohibited medical debt in credit reports....more
In a sweeping announcement, the Consumer Financial Protection Bureau (CFPB) revoked nearly 70 interpretive rules, advisory opinions, and guidance documents on May 12, 2025. The Federal Register Notice adds to the pullback on...more
Florida Gov. Ron DeSantis recently signed legislation making it clear that debt collection emails sent between 9 p.m. and 8 a.m. do not violate Florida law....more
On May 12, the CFPB formally withdrew nearly 70 guidance materials—including policy statements, advisory opinions, circulars, and interpretive rules—through a Federal Register notice issued by Acting Director Russell...more
This week, the Consumer Financial Protection Bureau (CFPB or Bureau) released a memo to staff outlining its new supervision and enforcement priorities for 2025....more
Utah and Arkansas have enacted new legislation governing earned wage access (EWA) services, establishing state-level registration obligations and consumer protection standards. Both laws clarify that EWA services are not...more
In a recent decision from the U.S. District Court for the Northern District of Indiana, the court granted a motion to dismiss in favor of a debt collection law firm and one of its attorneys who were not licensed as debt...more
Utah has become the seventh state (and the second in 2025) to enact a law that establishes a financial services oversight regime for earned wage access services, also known as on-demand pay services, which allow workers to...more
On March 20, the Arkansas governor signed into law Arkansas Act 347, known as the Earned Wage Access Services Act. Sponsored by Representative David Ray (R) and Senator Ben Gilmore (R), this legislation aims to regulate...more
Recently, the California DFPI adopted updated regulations concerning the state’s Debt Collection Licensing Act. The DFPI established definitions and specific requirements for the term “net proceeds generated by California...more
The Utah Legislature has passed H.B. 279, known as the Earned Wage Access Services Act. Sponsored by Representative A. Cory Maloy (R) and Senator Chris H. Wilson (R), this legislation aims to regulate earned wage access (EWA)...more
On February 14, the Governor of New York signed into law AB 431 (the “Act”), amending Article 9, Sections 901, 902 and 904 of the financial services law relating to private education debt reporting. The Act requires student...more
We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures, consumer financial services providers faced a challenging...more
The Consumer Financial Protection Bureau (CFPB or Bureau) requested and was granted a 90-day stay in the litigation involving trade associations Cornerstone Credit Union League (Cornerstone) and the Consumer Data Industry...more
Clark Hill’s Financial Services and Regulatory Compliance Group has authored a whitepaper for debt settlement companies considering engaging a third-party payment processor for managing accounts and handling financial...more
In January 2025, the New York City Department of Consumer and Worker Protection (DCWP) issued a Notice of Change of Effective Date (Notice), further delaying the effective date for the final rules relating to debt collectors...more
As discussed here, in February 2023, the Consumer Financial Protection Bureau (CFPB or Bureau) launched the auto finance data pilot and issued nine market monitoring orders to three banks, three finance companies, and three...more
In our previous post, we discussed the New York City Department of Consumer and Worker Protection’s (NYC DCWP) decision to delay the enforcement of the amended debt collection rules from December 1, 2024, to April 1, 2025....more
One of the primary challenges with working in the U.S. financial services space is keeping up with the ever-changing federal and state regulatory landscape. Juggling the day-to-day fire drills while staying atop of regulatory...more
This week, we discussed the constitutional legal challenge against New York City’s recently amended debt collection rules, which were scheduled to go into effect on December 1, 2024. These rules would stringently regulate...more
New York City’s recently amended debt collection rules — scheduled to go into effect on December 1, 2024 and which would stringently regulate various debt collection activities by debt collectors operating in the city — have...more