On September 10, 2026, the FTC’s Bureau of Consumer Protection (BCP or Bureau) announced a new BCP Rule Guidance Program (Program) that gives businesses, trade associations, and other stakeholders a new mechanism for bringing problems with FTC rules directly to the Bureau’s attention. The program invites submissions identifying genuine ambiguities in FTC rules, substantive conflicts between an FTC rule and an existing statute or another FTC rule, and other significant problems with the FTC rules.… Continue Reading

The Federal Trade Commission’s Bureau of Consumer Protection has created a new process that could provide businesses and other stakeholders with a meaningful avenue for raising concerns about the FTC’s consumer protection rules.

The premise is straightforward. If an FTC rule is unclear, conflicts with another legal requirement, or otherwise presents a significant problem, the agency should know about it.… Continue Reading

FinCEN and the staffs of the Fed, FDIC, OCC, and NCUA, have jointly issued two FAQs addressing the use of verifiable digital credentials (VDCs), including state-issued mobile driver’s licenses (mDLs), to verify customer identities under the Customer Identification Program (CIP) Rule.

The principal clarification is that an unexpired, government-issued VDC, such as an mDL, may qualify as “government-issued identification” for purposes of the CIP Rule, provided that the VDC evidences nationality or residence and bears a photograph, the institution has the technology or systems necessary to extract the appropriate information, and the institution’s CIP permits its use.… Continue Reading

The Mortgage Bankers Association (MBA) recently filed a lawsuit in the U.S. district court for the district of New Jersey challenging the disparate impact rules adopted by the state.

In December 2025, the New Jersey Division on Civil Rights (DCR) adopted Rules Pertaining to Disparate Impact Discrimination under the New Jersey Law Against Discrimination.… Continue Reading

The Federal Trade Commission and state of Connecticut recently secured a $4 million settlement with Chase Nissan LLC and its owners and management over allegations that the business was collecting fees without consumer authorization, including double charging for “certified pre-owned vehicles.”

The company did business as Manchester City Nissan. The Stipulated Order for a Permanent Injunction, Monetary Judgment and Other Relief was filed in the U.S.… Continue Reading

Executive Summary

The Conference of State Bank Supervisors (CSBS), the nationwide organization representing state banking and financial regulators, has endorsed legislation that would clarify a critical issue concerning the scope of Section 525 of the Depository Institutions Deregulation and Monetary Control Act of 1980 (DIDMCA). The development comes as the House Financial Services Committee prepares to mark up H.R.… Continue Reading

Changes at the CFPB have caused a backlog of consumer complaints, the CFPB’s Office of Inspector (OIG) said, in a report.

Stop-work orders also resulted in CFPB staff temporarily not performing enforcement, supervision and other functions, but workforce-reduction actions had limited impact on bureau operations because of court intervention, the OIG said.… Continue Reading

The future of the Consumer Financial Protection Bureau (CFPB or Bureau) has rarely been more uncertain. Since its creation, the CFPB has been at the center of intense political and policy debate, with its priorities changing dramatically as administrations change. The events of the past year or so under the leadership of Acting Directors chosen by President Trump, however, have taken that policy whiplash to a new level.… Continue Reading

On August 11, 2026, the Colorado Department of Law published its much anticipated Automated Decision-Making Technology (ADMT) and Conversational AI Service Rules (the “Draft Rules”). The ADMT Draft Rules provide guidance on the newly amended Colorado AI Act.

The Draft Rules – which were required to be written on an expedited basis by the amended Act – cover various different issues that will be critical to deployer and developer compliance.… Continue Reading

Colorado Attorney General Philip Weiser and Uniform Consumer Credit Code Administrator Martha Fulford have sued Activehours, Inc., doing business as EarnIn, alleging that EarnIn’s direct-to-consumer “Cash Out” earned-wage-access product is a consumer loan subject to Colorado’s lending laws.

The complaint, filed on August 27, 2026, in the Denver District Court for the City and County of Denver, alleges that EarnIn made more than 3.1 million transactions to Colorado consumers between January 2023 and July 2025, advancing approximately $300 million and collecting more than $16 million in tips and expedited-transfer fees.… Continue Reading