2026

The U.S. Department of Justice (DOJ) has issued an interim final rule extending the compliance dates for its 2024 Americans with Disabilities Act (ADA) Title II website and mobile application accessibility regulations for state and local governments. This development is noteworthy for anyone watching the long‑running debate over web accessibility standards, as well as the potential implication of this rulemaking for a future DOJ proposed rule governing public accommodations under Title III of the ADA.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by colleagues Joe DeFazio, Brad Knapp, and Punit Marwaha for a practical introduction to consumer bankruptcy from the creditor’s perspective. The panel walks through the core bankruptcy chapters that consumer financial services companies encounter most often and explains how the automatic stay, co-debtor stay, and discharge injunction operate in real-world servicing and collection environments. They discuss treatment of secured and unsecured debts, reaffirmation agreements, and hot-button issues like the dischargeability of qualified education loans. The conversation also highlights common traps for mortgage servicers, auto lenders, and unsecured creditors, including repossessions, garnishments, foreclosure timing, and plan objections, as well as preference actions and clawbacks.

In this special joint episode of Payments Pros and The Consumer Finance Podcast, guest host Taylor Gess joins Chris Willis and Lori Sommerfield to unpack fair lending risks in point-of-sale finance. They explain how traditional fair lending concepts under the Equal Credit Opportunity Act and Fair Housing Act play out when merchants interact directly with consumers, highlighting risks around discouraging credit applications, discretionary offers, differential assistance, and steering between prime and subprime products. The conversation explores practical risk mitigation tools, such as standardized sales scripts and consumer disclosures, merchant training, and attorney-directed mystery shopping, along with lessons drawn from unfair or deceptive acts or practices enforcement in point-of-sale settings.

On April 22, the Consumer Financial Protection Bureau (CFPB or Bureau) issued its final rewrite of Subpart A of Regulation B (Reg B) under the Equal Credit Opportunity Act (ECOA), which eliminates disparate impact from enforcement of ECOA, clarifies the prohibition on discouraging prospective applicants, and establishes new restrictions on special purpose credit programs (SPCPs). The Bureau has largely finalized the rule as proposed, with only clarifying edits rather than substantive revisions. Notably, the Bureau did so after receiving approximately 64,500 comments on the proposal from industry, consumer advocates, state attorneys general, and members of Congress. The rule will become effective 90 days after publication in the Federal Register.

On March 13, the Consumer Financial Protection Bureau (CFPB or Bureau) released its draft Strategic Plan for FY 2026–2030 and accepted public comment through April 17. The plan, required under the Government Performance and Results Act, sets the Bureau’s mission and priorities for the next four years and explicitly aligns the CFPB’s regulatory strategy with President Trump’s pro‑growth, deregulatory agenda.

On April 17, the Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Federal Reserve), and Federal Deposit Insurance Corporation (FDIC) (collectively, the federal agencies) issued revised interagency guidance on model risk management. The guidance updates and consolidates supervisory expectations for how banks manage the growing use of models across their businesses and effectively manage those risks, while rescinding prior guidance issued by each agency. The updated guidance is principles-based and risk-based, rather than prescriptive, and the federal banking agencies emphasize that model risk management should be tailored to a bank’s model risk profile, as well as the size and complexity of its operations. The agencies further state that non-compliance with the guidance itself will not, standing alone, result in supervisory criticism. That said, weak model risk management can still lead to findings of unsafe or unsound practices or violations of law.

New York has now enacted a statewide ban that, with limited exceptions, prohibits employers from using consumer credit history in hiring and other employment decisions. Effective April 18, 2026, the law amends the state’s General Business Law to make it an unlawful discriminatory practice for most employers to request or rely on an applicant’s or employee’s credit information when making employment decisions.

Delaware is positioning itself at the center of digital asset and stablecoin innovation with a coordinated package of legislation aimed at modernizing its banking code and creating a comprehensive framework for payment stablecoins. Senate Bill 16, the “Delaware Banking Modernization Act of 2026,” (SB 16) and Senate Bill 19, the “Delaware Payment Stablecoin Act,” (SB 19) were introduced on March 23, 2026, and are currently moving through the General Assembly. If enacted, both measures would take effect immediately, with implementation required by the earlier of one year after enactment or the issuance of final regulations by the State Bank Commissioner.

Recently, the Sixth Circuit issued a significant ERISA preemption ruling for employers and pharmacy benefit managers (PBMs). The court held that Tennessee’s PBM laws, which require “any willing” pharmacy access and limiting incentives that steer members to plan‑favored pharmacies, are preempted as applied to self‑funded ERISA plans. The ruling draws a clear line between permissible PBM cost regulation and impermissible interference with plan design and administration.