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.
Federal Activities
On November 21, the Consumer Financial Protection Bureau (CFPB) released its Fair Debt Collection Practices Act (FDCPA) Annual Report 2025, summarizing 2024 activity. The CFPB received about 207,800 debt collection complaints (7% of all complaints), with “attempts to collect debt not owed” the most common issue and credit card debt the most complained-about category after “I do not know.” Companies responded to 97% of complaints sent to them, most often closing with explanation or non‑monetary relief. Supervisory examinations of larger participants found violations, including failures to provide timely validation notices, use of misleading names and missing required disclosures, contacting consumers at inconvenient times, harassing conduct despite requests to stop, failure to honor requests not to use a specific medium or number, and unfair practices stemming from misdocumented statutes of limitations on credit card debt sold to collectors. Legally, the CFPB and Federal Trade Commission (FTC) filed amicus briefs, with the U.S. Court of Appeals for the Eleventh Circuit affirming that pay‑to‑pay fees are prohibited unless expressly authorized by agreement or law and a federal court rejecting payoff statement fees. The CFPB withdrew a medical‑debt advisory opinion in 2025. Enforcement activity in 2024 was led by the FTC, while the CFPB announced no public FDCPA actions. The report also details consumer education and outreach (including heavy “Ask CFPB” usage), research on medical collections removal and credit-score impacts, targeted initiatives for older Americans, servicemembers, students, and Native communities, and continued market monitoring and implementation feedback on Regulation F. For more information, click here.
On November 21, the Federal Reserve Board announced it will extend the comment period on its proposal to improve stress test model and scenario transparency and accountability until February 21, 2026, citing the need to give interested parties more time to analyze the issues and prepare feedback. The original deadline was January 22, 2026, and the separate deadline for comments on the 2026 stress test scenarios remains December 1, 2025, as outlined in the related Federal Register notice on enhanced transparency and public accountability of supervisory stress test models and scenarios. For more information, click here.
On November 21, the Federal Reserve Board released results from its Senior Financial Officer Survey, capturing how banks manage reserve balances and their expectations for balance sheet size and composition, deposit pricing strategies, and developments in stablecoins and digital assets. Conducted with the New York Fed between September 19 and 29, 2025, the survey includes responses from institutions holding roughly three‑quarters of total system reserve balances. For more information, click here.
On November 21, Federal Reserve Vice Chair Philip Jefferson, speaking at the Cleveland Fed’s Financial Stability Conference, said AI’s rapid diffusion could both raise productivity and ease inflationary pressures while also displacing some workers, leaving the net employment effects uncertain and warranting humility in monetary policy as the Fed distinguishes cyclical dynamics from structural change. He assessed the financial system as sound and resilient but noted the Fed’s Financial Stability Report found 30% of market contacts now cite a potential turn in AI sentiment as a salient risk (up from 9% in spring), which could tighten financial conditions. Comparing today to the late‑1990s dot‑com era, Jefferson highlighted key differences: AI‑linked firms generally have established earnings, lower price‑to‑earnings ratios than dot‑com peaks, and a narrower public cohort, with limited leverage so far — though debt financing may rise to fund data centers and talent — making a replay of the dot‑com boom less likely. He concluded that ensuring the AI transition occurs within a stable financial system is essential to achieving the Fed’s dual mandate of maximum employment and price stability. For more information, click here.
On November 21, the Securities and Exchange Commission (SEC) announced that its Crypto Task Force has rescheduled the Financial Surveillance and Privacy Roundtable, originally slated for October, to Monday, December 15 from 1 to 5 p.m. ET at SEC headquarters. The event is open to the public, will be webcast on sec.gov, requires registration for in-person attendance (not for online viewing), and, per Task Force Head Commissioner Hester Peirce, aims to advance sound privacy policies and highlight tools that help Americans protect their data. For more information, click here.
On November 20, the CFPB will hand off its remaining enforcement lawsuits and other active litigation to the U.S. Department of Justice (DOJ) as the CFPB prepares for a potential funding lapse. CFPB staff were informed that DOJ will begin assuming matters from the CFPB’s enforcement and legal divisions in the coming weeks, with transfer logistics to be worked out. It remains unclear whether all pending cases will survive the transition or whether case schedules and continuity will be affected. For more information, click here.
On November 20, SEC Commissioner Mark Uyeda, speaking at the ICI Retail Alternatives and Closed‑End Funds Conference, argued that 401(k) plans face a “diversification deficit” and should be able to allocate prudently to private investments — such as private equity, private credit, venture capital, infrastructure, and real estate — to improve risk‑adjusted returns amid rising public‑market concentration and target‑date funds’ typical reliance on open‑end, public strategies. Citing institutional results and modern portfolio theory, he rejected a “zero exposure” presumption, urged ERISA fiduciary guardrails over outright exclusion, noted recent policy moves to broaden access (including the Trump Administration’s executive order), and called for litigation reform to curb hindsight‑driven ERISA suits that chill innovation. Uyeda also pressed for coordinated SEC–Department of Labor frameworks on disclosures, fees, valuation, conflicts, and custody so defined‑contribution savers can access private markets responsibly while maintaining robust investor protections. For more information, click here.
On November 20, the U.S. Senate Committee on Agriculture, Nutrition, and Forestry advanced Michael Selig’s nomination to serve as chairman and commissioner of the Commodity Futures Trading Commission (CFTC) with Senator John Boozman (R-AR) calling it a critical moment as Congress weighs expanding the CFTC’s authority and stressing that strong leadership is essential to implement new policies and responsibilities. Boozman further praised Selig as the right person to strike the balance and urged swift Senate confirmation. Selig’s nomination now heads to the full Senate for consideration. For more information, click here.
On November 20, U.S. Representative Warren Davidson (R-OH) introduced the Bitcoin for America Act, which would allow Americans to pay federal taxes in Bitcoin and direct all such payments into a Strategic Bitcoin Reserve — an initiative he says will modernize U.S. finance, strengthen long-term resilience, and position the U.S. for global digital asset leadership. Citing Bitcoin’s fixed 21 million-coin supply, record of appreciation versus inflationary currencies, and decentralized, permissionless access that could broaden participation (including among the unbanked), Davidson argues that channeling tax-paid Bitcoin into the Reserve would diversify U.S. assets, protect against dollar erosion, bolster the national balance sheet, and reduce reliance on debt, while ensuring the U.S. keeps pace as other major nations accumulate Bitcoin. For more information, click here.
On November 20, U.S. Senate Agriculture Committee Chairman John Boozman (R-AR) and Senator Cory Booker (D-NJ) released a bipartisan market structure discussion draft that would give the CFTC new authority to regulate the spot market for digital commodities, building on the House-passed CLARITY Act. The draft outlines a CFTC-led regime with a clear definition of “digital commodities,” robust consumer protections (including fund segregation, conflict safeguards, disclosures, and limits on affiliated trading), a trading registration framework to support liquid, resilient markets, mandated CFTC–SEC coordination, protections for self-custody and innovative technology, and a new funding stream for the CFTC to stand up the program. Boozman emphasized that the CFTC is the right agency and pledged to work with colleagues and the administration to ensure sufficient staffing and resources, while Booker highlighted the need to protect consumers and market integrity, and flagged outstanding concerns — including resource adequacy, commissioner balance, preventing regulatory arbitrage, and guardrails against corruption — inviting stakeholder feedback as unresolved issues remain bracketed in the draft. For more information, click here.
On November 20, Federal Reserve Governor Lisa Cook, speaking at Georgetown’s Psaros Center, said the financial system remains resilient, but highlighted key vulnerabilities such as elevated asset valuations across equities, credit, leveraged loans, and housing; rapid growth and rising complexity in private credit that could transmit losses through leveraged and interconnected funding chains; and the expanding hedge fund footprint in the U.S. Treasury market, where leveraged relative‑value trades funded via short‑term repo could amplify stress during volatility. She also examined generative AI’s implications for market stability, noting potential benefits for price discovery and reduced herding alongside risks of correlated trading, opacity (“black box” concerns), and manipulation, while pointing to improving surveillance and venue safeguards. Cook emphasized that maintaining financial stability is essential to the Fed’s dual mandate and that ongoing monitoring and prudent policy can navigate these emerging risks amid significant technological change. For more information, click here.
On November 20, a coalition of digital asset and blockchain organizations sent a letter to President Donald Trump praising first‑year actions (IRS Broker Rule nullification, the GENIUS Act, and rescission of DOL’s 2022 crypto guidance) and urging immediate, whole‑of‑government steps to cement U.S. leadership: Treasury/IRS tax clarity on mining and staking (taxed at disposition), nonrecognition for bridging/wrapping, airdrops/forks/rebases treatment, collateral/liquidation rules, a de minimis exemption for small purchases, streamlined charitable donations, foreign trading safe harbor, R&D credit eligibility, and delaying §6050I rules; regulatory clarity from CFPB (reaffirm broad §1033 data rights and fee ban), the SEC (expedite its agenda; issue no‑action/exemptive relief protecting open, permissionless protocol/front‑end developers; embrace self‑custody), plus safe harbors/sandboxes for DeFi; coordinated SEC–CFTC exemptive relief, Treasury/NIST cyber and illicit‑finance collaboration, updated FinCEN guidance confirming the Bank Secrecy Act does not cover noncustodial software, and disavowal of the proposed “mixing” special measure; and DOJ reforms to end “regulation by prosecution,” extend Section 230‑style protections to DeFi developers, and dismiss charges against Roman Storm, underscoring that publishing open‑source code is protected speech. For more information, click here.
On November 19, Trump nominated Stuart Levenbach, an energy official at the Office of Management and Budget (OMB), to serve a five-year term as permanent director of the CFPB. Levenbach’s experience is in natural resources and energy policy rather than financial regulation, and he would inherit an agency facing profound uncertainty after months of leadership turmoil, enforcement retrenchment, and dwindling finances.The next day, U.S. House Financial Services Committee Ranking Member Maxine Waters blasted the nomination as a “sham” aimed at extending CFPB Acting Director Russell Vought’s control of the CFPB without Senate confirmation and furthering an effort to “gut” the agency. She also condemned the administration’s legal theory that the CFPB cannot draw funds from the Federal Reserve and criticized moves to curtail small‑business loan data collection, pledging that Committee Democrats will fight to preserve consumer protections. For more information, click here and here.
On November 19, the Senate Banking Committee voted 13–11 to advance Travis Hill’s nomination to be Federal Deposit Insurance Corporation (FDIC) chair. Hill, currently acting chair and formerly vice chair, highlighted at his October hearing his role in deregulatory efforts and priorities to refocus supervision on material financial risks over process, strengthen large-bank resolution readiness, and adjust the capital framework. The committee also advanced the nominations of Joseph Gormley to lead Ginnie Mae, Francis Cassidy to be a HUD assistant secretary, and Paul Hollis to be director of the U.S. Mint. For more information, click here.
On November 19, Senators Elizabeth Warren, Ron Wyden, and Richard Blumenthal wrote to Vought warning that the CFPB appears poised to gut the bipartisan Personal Financial Data Rights rule finalized in 2024, urging the CFPB to reinstate the rule and preserve consumers’ free access to their own data and the ability to authorize a broad range of third parties to use that data, while prohibiting bank-imposed fees that would choke off competition and harm innovation. The senators cited recent litigation posture changes, industry pressure, and examples of exorbitant access fees as evidence of likely consumer harm and anticompetitive outcomes. Five days earlier, Hill and Vice Chairman Bill Huizenga of the House Financial Services Committee submitted a letter to the CFPB urging robust, consumer-directed data portability under Dodd-Frank §1033, interpreting “representative” to include nonfiduciary entities, anchoring privacy and security in GLBA’s uniform standards to avoid duplicative regimes, and allowing practical flexibility on access methods (including APIs and, where needed, screen scraping) to support smaller institutions. The letter concluded with support for a durable framework that advances consumer control without upending the existing ecosystem. For more information, click here and here.
On November 19, the Office of Financial Research delivered its 2025 Annual Report to Congress, analyzing U.S. financial stability risks and detailing organizational changes over FY 2025 (October 1, 2024, through September 30, 2025), including a smaller workforce, budget reductions aligned with administration goals, and efficiency gains from AI. The report highlights persistent technology and cyber vulnerabilities, especially via third‑party providers and propagation across financial and information networks; unusually low corporate debt spreads and stabilizing commercial real estate alongside elevated subprime household delinquencies; fading concerns over banks’ unrealized securities losses, concentrated office‑mortgage credit risk at large banks, and rapidly rising hedge fund borrowing and leverage in macro and relative‑value strategies; resilient market functioning, with Treasury markets performing well amid April volatility, high equity price‑to‑earnings ratios, and robust liquidity from proprietary trading firms; and money‑market developments, including new OFR data collection on non‑centrally cleared bilateral repo, reduced institutional prime money market fund balances, and continued predominance of financial‑firm and asset‑backed commercial paper issuance. For more information, click here.
On November 19, the House Financial Services Committee, led by Hill, examined the U.S. deposit insurance framework, weighing proposals to raise coverage limits amid concerns over unclear FDIC data (e.g., account classifications and insured vs. uninsured reporting), implementation costs for smaller banks, and potential moral hazard. Members noted that more than 99% of deposits are already insured under current limits and stressed preserving a diverse banking ecosystem (community, midsize, regional, and GSIBs) while avoiding one-size-fits-all reforms. Witnesses highlighted data gaps and contagion risks in a real‑time, digital environment; warned that accounting choices to spread costs over 10 years could mask reserve‑ratio pressures and expose small banks to special assessments; urged clarity and proportionality to reduce regulatory burden on community banks; and split on raising limits — some opposing broader guarantees as costly and risk‑inducing, others advocating targeted insurance for business operating accounts to reduce run risk and keep local capital working. For more information, click here.
On November 19, the Office of Information and Regulatory Affairs received for Executive Order 12866 review the Office of the Comptroller of the Currency’s (OCC) proposed rule titled “Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments,” which is at the proposed rule stage and carries no legal deadline. For more information, click here.
On November 18, the Federal Reserve Board released new supervisory operating principles to enhance bank supervision by focusing examiners on material financial risks to safety and soundness and taking timely, proportionate action to address them. Vice Chair for Supervision Michelle Bowman emphasized the approach “sharpens” rather than narrows supervision, anchoring it in transparency, accountability, and fairness. The principles align examinations and ratings to core financial risks, reduce duplication among supervisors, and streamline remediation of cited issues. The Federal Reserve is training examiners for prompt implementation, and supervision leadership plans to refine and, where appropriate, formalize the principles through public guidance or regulatory changes. For more information, click here.
On November 18, Acting CFTC Chairman Caroline Pham delivered a keynote at FIA EXPO outlining the agency’s market‑structure and innovation agenda and a 12‑month “Crypto Sprint” to bring digital assets inside existing U.S. regulatory perimeters: listed spot crypto trading on designated contract markets by year‑end; guidance to enable tokenized collateral, including qualified payment stablecoins, by year‑end with DCOs going live in early 2026; and a rulemaking to make technical amendments for collateral, margin, clearing, settlement, reporting, and recordkeeping to support blockchain/tokenization by August 2026. Pham detailed recent actions to reduce swaps‑market burdens (interpretive letters, procedures, proposed rule amendments, targeted no‑action relief, and withdrawals of legacy proposals), strengthen innovation and oversight (FBOT registration clarity, volatility controls, risk‑management advisories, FCM FAQs, adoption of Nasdaq surveillance), and revive SEC–CFTC coordination (a joint roundtable and harmonization workstreams). She tied the roadmap to the President’s Working Group report and the GENIUS Act’s stablecoin framework, encouraged DCOs/FCMs to treat qualified payment stablecoins and tokenized money market funds as eligible margin and settlement assets with appropriate haircuts, custody, and liquidity safeguards, and emphasized technology‑neutral, activity‑based regulation to modernize U.S. markets without compromising integrity or customer protection. For more information, click here.
On November 18, the OCC issued Interpretive Letter 1186 confirming that national banks may pay blockchain “network” or “gas” fees to facilitate otherwise permissible activities and may hold, as principal on balance sheet, the amounts of crypto‑assets reasonably needed to cover anticipated network fees. The letter also permits banks to hold crypto‑assets as principal for testing otherwise permissible crypto‑asset-related platforms (whether developed internally or obtained from third parties), provided all such activities are conducted in a safe and sound manner and comply with applicable law. For more information, click here.
On November 17, the U.S. Department of Justice released its 2025 Annual Report to Congress on Activities to Combat Elder Fraud and Abuse, highlighting more than 280 enforcement actions against over 600 defendants, domestic and overseas, who attempted to steal or stole over $2 billion from more than one million older Americans, as well as actions holding multiple nursing home operators accountable for grossly substandard care. The DOJ expanded capacity through the first National Elder Abuse Multidisciplinary Team Summit (nearly 400 participants), recovered or froze millions for victims, and, via VOCA grants, supported more than 4,000 victim assistance organizations serving nearly 200,000 older victims. It also launched the first National Elder Abuse Victim Services Needs Assessment. Public outreach included nearly 1,200 events reaching about 15 million Americans, underscoring DOJ’s commitment to enforcement, victim services, capacity building, and prevention. For more information, click here.
On November 17, the FTC announced a final order permanently banning Seek Capital and its CEO from offering business financing, debt relief, and credit repair services after the agency alleged the firm deceived entrepreneurs by promising loans or lines of credit and instead charging thousands to open credit cards while harming credit scores and imposing undisclosed fees. A federal court granted most of the FTC’s summary judgment, finding misrepresentations that violated the FTC Act and Telemarketing Sales Rule, contracts that violated the Consumer Review Fairness Act, and Ferman’s personal liability. The order imposes a $48,280,328 monetary judgment (partially suspended for inability to pay, due in full if finances are misrepresented), bars misrepresentations, billing without informed consent, TSR violations, and restrictions on consumer reviews, and was approved 3–0 by the commission. For more information, click here.
On November 14, the Federal Reserve issued its 35th annual Report to Congress on the profitability of credit card operations, finding that specialized “credit card banks” posted a 2024 pretax return on assets of 3.87% (up from 3.31% in 2023) driven by higher interest income and reduced loan-loss provisioning (3.62% vs. 3.92%), far outpacing the 1.38% ROA for all banks. The report notes eight monoline credit card banks held 29% of balances at year-end 2024 (down from 42 banks holding 77% in 1996), with top 10 issuers now controlling 83% of balances, consumers carrying $1.4 trillion in revolving credit against more than $5 trillion in available limits, and market activity totaling 64.5 billion transactions and over $6.2 trillion in volume. Delinquencies rose early in 2024 before edging down, while charge-offs remained above pre-pandemic norms. Acquisition has shifted heavily to digital channels (with 2.8 billion direct-mail offers still significant), and usage trends include buy-now-pay-later growth and post‑transaction installment features. On pricing, average nominal rates across all accounts held near 21.5% and about 22.8% for accounts incurring interest at year-end 2024, despite a decline in the two‑year Treasury yield to roughly 4.2%, underscoring sustained high APRs amid evolving credit card market structure and regulation. For more information, click here.
On November 13, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN), in coordination with the Government of Mexico, targeted the Hysa Organized Crime Group (HOCG) and cartel-linked money laundering through Mexico’s gambling sector, with OFAC sanctioning 27 individuals and entities, including HOCG family members and key businesses, thereby blocking their U.S. property and prohibiting U.S. persons from transacting with them, and warning of potential secondary sanctions for foreign financial institutions. Concurrently, FinCEN proposed a USA PATRIOT Act section 311 special measure to cut off 10 named Mexico-based gambling establishments from the U.S. financial system by restricting correspondent account use and requiring heightened due diligence to guard against laundering. Treasury underscored that sanctions aim to change behavior and outlined the process for removal from the SDN List, while inviting public comment on FinCEN’s NPRM via regulations.gov. For more information, click here.
State Activities
On November 20, the Illinois Supreme Court narrowly construed private rights of action under the federal Fair Credit Reporting Act (FCRA), creating a de facto “concrete injury” requirement for claims under the FCRA and potentially other federal statutes with similar language authorizing rights of action. Although Article III’s concrete-injury requirement has become familiar in federal courts over the last decade, Illinois courts had not previously imposed such a requirement in cases involving statutory rights of action. The court in Fausett v. Walgreen Co., held that the FCRA does not explicitly authorize consumers to sue for violations, so the law did not authorize consumer lawsuits unless the consumer could show that a violation caused them a concrete injury. This ruling will significantly narrow consumers’ ability to bring no-injury claims under similar statutes in Illinois state courts. For more information, click here.
On November 19, the California Privacy Protection Agency announced a new Data Broker Enforcement Strike Force within its Enforcement Division to investigate privacy violations by data brokers, including compliance with the Delete Act’s registration requirement and the California Consumer Privacy Act (CCPA). Building on a 2024 investigative sweep that produced a record number of actions, the Strike Force adds resources and intensity to pursue further cases, with enforcement head Michael Macko pledging a “strike force” approach and Executive Director Tom Kemp highlighting the unique risks of industrial‑scale data collection and sales. The Delete Act requires data brokers to register and pay annual fees that fund the California Data Broker Registry and the forthcoming Delete Request and Opt‑Out Platform (DROP), which will let consumers submit a single deletion request across all data brokers starting January 2026. For more information, click here.