Marika is an associate in the firm’s White Collar Litigation + Investigations practice.
Christopher Carlson
Chris represents clients in regulatory, civil, and criminal investigations and litigation. In his practice, Chris regularly employs his prior regulatory experience to benefit clients who are interacting with and being investigated by state attorneys general.
Financial Services Industry 2025 Digital Assets Year in Review
In 2025, the U.S. digital asset landscape evolved more dramatically than in any year since the industry’s inception. A pro‑innovation White House, an active Congress, and key regulators — including the U.S. Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), the Office of the Comptroller of the Currency (OCC), the Department of the Treasury (Treasury), the Board of Governors of the Federal Reserve (the Fed), and the Federal Deposit Insurance Corporation (FDIC) — began to move away from a purely “regulation by enforcement” model toward a more defined framework for crypto markets. This shift has been anchored by stablecoin legislation, evolving custody and market structure expectations, and emerging guidance on token classification.
At the same time, financial crimes enforcement remained vigorous, privacy and cybersecurity requirements grew more complex, and state regulators continued to expand their role as frontline consumer protection and licensing authorities. For digital asset industry participants, the result is a market that offers meaningful opportunities for innovation and growth, even as regulatory uncertainty persists while much‑needed market structure legislation works its way through Congress. In the interim, industry stakeholders must continue to navigate overlapping federal and state regimes with care.
Troutman Pepper Locke’s Digital Assets team closely tracks these developments across agencies and jurisdictions and advises clients on the full spectrum of digital asset issues, including transactions, product development, litigation, enforcement, compliance, and strategic engagement with key stakeholders. Our 2025 Digital Assets Year in Review provides a comprehensive overview of the most consequential developments of the past year and highlights the themes that matter most to market participants, including stablecoins and payments, custody and market structure, token classification, financial crimes and sanctions, privacy and cybersecurity, and state‑level licensing and consumer protection. We hope this report serves as a practical tool to support those efforts.
To access the report, please click here.
State AGs in the Driver’s Seat: Auto Finance Enforcement in the Trump 2.0 Era
In this episode of Moving the Metal, hosts Brooke Conkle and Chris Capurso are joined by Troutman colleagues Chris Carlson and Nam Kang from the firm’s RISE Practice Group to unpack what “Trump 2.0” really means for dealers and auto finance companies. With the Consumer Financial Protection Bureau (CFPB) and other federal regulators pulling back, the group explains how state attorneys general (AGs) and state financial regulators are rapidly filling the void — often led by former CFPB staff now embedded in state offices — and why that creates a complex patchwork of unfair or deceptive acts or practices standards and enforcement approaches across 50 states. They discuss hot-button themes like affordability, junk fees, mini-CFPBs, and the growing role of state working groups, as well as how state AGs are leveraging prior CFPB theories, the California CARS rule, and copy‑and‑paste complaints.
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New York Expands Consumer Protection Law Giving the AG Broader Powers
On December 19, 2025, New York Governor Kathy Hochul signed into law the Fostering Affordability and Integrity through Reasonable (FAIR) Business Practices Act. The FAIR Act, which was proposed by Attorney General (AG) Tish James, represents the first major update to the state’s primary consumer protection law in 45 years and significantly broadens the statute’s reach.
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New Jersey’s Data Deletion Law: Implications for Resold or Re-leased Vehicles
On July 28, the New Jersey Division of Consumer Affairs issued a reminder to more than 3,000 auto dealerships regarding their obligations under the New Jersey data deletion law, N.J.S.A. § 56:12-18.1. This law, enacted and effective in January 2024, requires dealerships to offer data deletion services for consumer information stored in vehicles accepted for resale or lease. Dealerships are now on notice of their compliance obligations under the law.
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Auto Finance Under the Microscope: Unpacking Landmark FTC and AG Settlements
In this episode, Brooke Conkle and Chris Capurso from Troutman Pepper Locke’s Consumer Financial Services Practice Group are joined by Chris Carlson, a partner in the Regulatory Investigations Strategy and Enforcement Practice Group. They delve into recent enforcement actions impacting the auto finance sector, including a landmark $20 million settlement involving the Federal Trade Commission and the Illinois attorney general against Leader Automotive Group. The discussion covers deceptive advertising, unauthorized add-on charges, fake online reviews, and the sale of gray market vehicles. Additionally, they explore a stipulated judgment the Connecticut attorney general reached with a national auto retailer. Tune in to understand the implications of these actions and what auto finance companies should take away from these regulatory developments.
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FTC and Illinois AG Secure $20M Settlement with Leader Automotive Group Over Allegedly Deceptive Practices
In a significant enforcement action, the Federal Trade Commission (FTC) and the Illinois Attorney General have reached a $20 million settlement with Leader Automotive Group and its Canadian parent company, AutoCanada, over allegations of widespread consumer fraud. If entered, this settlement will be the largest monetary judgment the FTC has secured against an auto dealer.
Continue Reading FTC and Illinois AG Secure $20M Settlement with Leader Automotive Group Over Allegedly Deceptive Practices
New Jersey Attorney General Releases Report on Republic First Bank’s Unlawful Redlining Practices
On October 29, New Jersey Attorney General Matthew Platkin and the state’s Division on Civil Rights (DCR) released a report detailing the findings of a multi-year investigation into Republic First Bank (Republic) and its alleged mortgage redlining practices. According to the report, the investigation revealed that Republic engaged in a pattern or practice of redlining against Black, Hispanic, and Asian communities in New Jersey, in violation of the New Jersey Law Against Discrimination.
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Minnesota Attorney General Shuts Down Debt Settlement Companies
On October 21, Minnesota Attorney General Keith Ellison announced a settlement with two debt settlement companies, Financial Solutions Group and Accelerated Debt Settlement.
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Investigation Tag Team: The FTC and the State of Arizona
In this episode, Chris Carlson, an associate in the Regulatory, Investigations, Strategy and Enforcement (RISE) practice, joins Brooke and Chris to discuss how federal and state regulators are collaborating on consumer protection investigations. The team discusses a recent order and action against an Arizona-based auto dealer for multiple Unfair or Deceptive Acts or Practices (UDAP) violations. While contemplating whether this is a growing trend, the trio meanders into discussions about the CARS Rule and the potential impact of November’s election on the industry.
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FTC and Arizona AG Reach $2.6 Million Settlement with Motor Vehicle Dealer Over Alleged Deceptive and Discriminatory Sales and Financing Practices
Yesterday, the Federal Trade Commission (FTC) and the State of Arizona announced a joint action against Coulter Motor Company, an Arizona-based motor vehicle dealership, and its former general manager, for allegedly engaging in deceptive pricing practices and discriminatory financing treatment of Latino consumers. The complaint alleges violations of the FTC Act, the Equal Credit Opportunity Act, and the Arizona Consumer Fraud Act. The defendants have agreed to a $2.6 million settlement, most of which will be used to provide refunds to affected consumers.
Continue Reading FTC and Arizona AG Reach $2.6 Million Settlement with Motor Vehicle Dealer Over Alleged Deceptive and Discriminatory Sales and Financing Practices