State Regulation

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The Office of the Comptroller of the Currency (OCC) is taking aim at another potential source of state regulatory interference with federally chartered financial institutions. In an October 29, 2026 letter to the Chair of the California Air Resources Board (CARB), Comptroller of the Currency Jonathan Gould urged California to exempt national banks and federal savings associations from two California climate-disclosure statutes.… Continue Reading

Pennsylvania has enacted legislation imposing new disclosure requirements on certain advertisements that use artificial intelligence (AI)-generated or AI-modified content. Senate Bill 806, now Act 99 of 2026, was signed into law by Governor Josh Shapiro on October 22, 2026. The statute, titled the Artificial Intelligence Deceptive Advertising Act, establishes a disclosure requirement for advertisers whose use of synthetic content creates a false consumer perception about the nature, origin, or authenticity of the goods or services being advertised.… Continue Reading

Oregon and nine other states argue that the OCC unlawfully preempted state interest-on-escrow laws, that Oregon is a proper venue, and that their challenge to the agency’s authority should proceed. The court expects to rule on the OCC’s motions by November 20.

Ten states challenging the Office of the Comptroller of the Currency’s (OCC) mortgage interest-on-escrow rules have opposed the agency’s motion to dismiss or transfer the case.… Continue Reading

California has once again expanded its regulation of financial services. On September 30, 2026, Governor Gavin Newsom signed Assembly Bill 2116, which will subject a broad range of commercial financing providers and brokers to licensing, substantive conduct requirements, and regulatory oversight by the California Department of Financial Protection and Innovation (DFPI).… Continue Reading

When Rohit Chopra left the Consumer Financial Protection Bureau earlier this year, there was considerable speculation about what he would do next. In May, Governor Gavin Newsom provided the answer: Chopra would become the inaugural Secretary of California’s newly created Business & Consumer Services Agency (BCSA).

Chopra was sworn in on July 1.… 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

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

As we have chronicled in our blog, states are increasingly moving to fill the consumer-protection void created by the CFPB’s dramatic retreat from supervision, enforcement and rulemaking. State legislatures are considering and enacting new consumer-finance protections; state attorneys general are bringing more enforcement actions under state UDAP and other laws, often in bipartisan and multistate coalitions; and state financial regulators are expanding their supervisory and enforcement efforts.… Continue Reading

Hearing will focus on whether Section 525 permits an opt-out state to regulate loans made by out-of-state state banks

On Wednesday, September 2, the House Financial Services Committee will hold a hearing entitled “Strengthening the American Economy: Promoting Growth, Opportunity, and Prosperity.” The hearing will begin at 10:00 a.m. ET in Room 2128 of the Rayburn House Office Building.… Continue Reading

The new California Business and Consumer Services Agency (BCSA), launched on July 1, 2026, will focus on improper practices that drive costs up for state residents, agency Secretary Rohit Chopra said, in a recent blog post.

“A key priority for the agency is to crack down on harmful and corrupt practices that wrongfully raise costs for families and honest businesses,” Chopra wrote.… Continue Reading