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Stefanie Jackman

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Stefanie takes a holistic approach to working with clients both through compliance counseling and assessment relating to consumer products and services, as well as serving as a zealous advocate in government inquiries, investigations, and consumer litigation.

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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.

In this joint episode of The Consumer Finance Podcast and Payments Pros, guest host Taylor Gess is joined by Stefanie Jackman to discuss amended debt collection regulations and restrictions for creditors, including tight communication limits and enhanced validation requirements. The conversation dives into the rise of coerced debt statutes, shortcomings of traditional identity theft frameworks, and how creditors should adjust training, intake, and escalation protocols to avoid reputational and legal risk. The discussion also explores state medical debt reporting bans, the preemption challenges, and cautious furnishing in the FCRA landscape.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by Consumer Financial Services Partners Stefanie Jackman and Nicholas O’Conner to dissect the shifting risk landscape for servicers, collectors, and debt buyers as federal scrutiny eases and state regulators surge to the forefront. As a segment of the Year in Review and Look Ahead series, the trio talks about Reg F’s post-Loper Bright staying power, the explosive growth of state medical debt restrictions and FCRA preemption battles, and the rapid spread of coerced debt/economic abuse statutes reshaping account handling. They also explore the evolving role of debt settlement companies and their use of AI, in addition to offering practical tips on building national policies and procedures to prepare for the next wave of litigation and enforcement.

This article was cited in the April 1, 2026 Multifamily Dive article, “FTC Seeks Public Input on Junk Fee Rule for Rental Housing.”

The Federal Trade Commission has announced an Advance Notice of Proposed Rulemaking (ANPRM) to explore a new rule governing unfair or deceptive rental housing fee practices. The initiative focuses on the widening gap between advertised rent and the total amounts renters actually pay once mandatory fees and charges are added. Once the ANPRM has been published in the Federal Register, comments will be accepted for 30 days. 

The New York City Department of Consumer and Worker Protection (NYC DCWP) has adopted a comprehensive set of amendments to its debt collection rules, effective September 1, 2026. The final rule clarifies that New York City’s consumer protection framework applies not only to traditional third‑party debt collectors and debt buyers, but also to original creditors once they engage in defined “debt collection procedures.” It also tightens limits on collection communications, expands validation and verification obligations, and adds targeted protections for medical and time‑barred debt. NYC DCWP will withdraw its prior August 2024 Notice of Adoption and treat this new rule as the governing framework going forward.

On February 23, the New York Department of Financial Services (DFS) issued a proposed new Part 423 to Title 3 of the NYCRR to implement New York Banking Law Article 14‑B for Buy-Now-Pay-Later (BNPL) lenders. The proposal would move BNPL firmly into New York’s credit system, imposing licensing, supervision, disclosure, data privacy, and underwriting requirements on both interest‑free and interest‑bearing BNPL products offered to New York consumers. If adopted, the rule would take effect 180 days after the notice of adoption is published in the State Register, with a short transitional period for existing BNPL providers. DFS is accepting pre-proposal comments through March 5, 2026, after which the proposed rule will be published in the New York state register for a formal 60-day comment period.

Colorado lawmakers are considering legislation that would significantly expand consumer protections around motor vehicle finance and sales. House Bill 26‑1261, introduced on February 19, 2026 and currently pending before the House Business Affairs & Labor Committee, would overhaul repossession timelines for certain “qualified motor vehicles,” restrict use of vehicle-disabling technology, and create a three‑business‑day right to return certain vehicles purchased from dealers.

On January 27, the Government Accountability Office (GAO) released a report, Consumer Financial Protection Bureau: Status of Reorganization Efforts (GAO‑26‑108448), that offers a detailed snapshot of the Consumer Financial Protection Bureau’s (CFPB or Bureau) ongoing downsizing and restructuring. This is the first of two GAO reports that focus on the CFPB’s reorganization and its ability to fulfill its statutory functions going forward.

In this special joint episode of The Consumer Finance Podcast and Payments Pros, guest host Taylor Gess talks to Troutman Pepper Locke colleagues Stefanie Jackman, Caleb Rosenberg, and Jeremy Sairsingh about student lending and income share agreements (ISAs). They highlight the “One Big Beautiful Bill” and its sweeping overhaul of federal student loan repayment options and borrowing caps, break down differences between ISAs and traditional loans, and explain why state lawmakers and regulators are increasingly focused on these products. The episode also includes practical takeaways on licensing, servicing, and the potential future of credit reporting for private student loans and ISAs, offering industry participants a roadmap for navigating both federal and state-level changes.

On January 12, the California Department of Financial Protection and Innovation (DFPI) issued a second invitation for comments on potential regulations under the California Consumer Financial Protection Law (CCFPL) that would require registration and reporting by firms engaged in consumer reporting and related data activities. Comments are due by February 26.