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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 July 14, the Federal Trade Commission (FTC) secured a court order aimed at halting allegedly deceptive practices against seven companies and three individuals operating the “Accelerated Debt” program. The defendants allegedly contacted consumers through telemarketing calls or in response to calls resulting from their mail and online ads and made false claims about their ability to substantially reduce consumer debts and misleading consumers about fees. The FTC alleged these actions violated the FTC Act, the Telemarketing Sales Rule, the Impersonation Rule, the Fair Credit Reporting Act (FCRA), and § 521 of the Gramm-Leach-Bliley Act by making false statements to get consumers’ financial account numbers. The court’s order includes a temporary restraining order, asset freeze, and the appointment of a temporary receiver to oversee the defendants’ business operations.

On July 14, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2025-16, announcing the removal of references to disparate impact liability from the “Fair Lending” booklet of the Comptroller’s Handbook and instructing examiners to cease examining banks for disparate impact liability. This change aligns with Executive Order (EO) 14281, issued by President Trump (discussed here), which aims to eliminate the use of disparate impact liability in all contexts at both the federal and state level.

On June 23, the Consumer Financial Protection Bureau (CFPB or Bureau) released an update to its 2015 report on Americans who did not have a credit record (credit invisibles) or who had insufficient credit history to have a credit score (“stale unscored” and “insufficient unscored”). The CFPB provided this update, driven by methodological corrections and enhanced data sources, in an effort to offer a more accurate depiction of the number of Americans with limited credit histories and highlight significant changes over the past decade.

Today, the Consumer Financial Protection Bureau (CFPB or Bureau) published a policy statement in the Federal Register outlining its approach to addressing criminally liable regulatory offenses. This publication comes in response to Executive Order 14294, issued by President Trump on May 9, 2025, which aims to combat overcriminalization in federal regulations.

On June 20, the Consumer Financial Protection Bureau (CFPB or Bureau) filed a statement of interest in support of converting the bankruptcy case of Synapse Financial Technologies, Inc. from Chapter 11 to Chapter 7, rather than dismissing it. This move comes amidst concerns over significant consumer harm stemming from Synapse’s alleged unfair practices in managing funds across its network of partner financial institutions. The shortfall between the money consumers had in their accounts at the time their accounts were frozen and the money that has been returned by the partner financial institutions may be as high as $95 million.

In a significant ruling today, the U.S. Supreme Court delivered its 6-3 opinion in McLaughlin Chiropractic Associates, Inc. v. McKesson Corporation, addressing the scope of judicial review under the Hobbs Act. The decision marks a pivotal moment in administrative law, particularly concerning the deference required to agency orders in enforcement proceedings. While the Supreme Court previously addressed whether the Hobbs Act applied in private litigation, it ultimately did not resolve whether a district court is required to follow a particular Federal Communications Commission (FCC) order interpreting the TCPA.

Today, the Consumer Financial Protection Bureau (CFPB or Bureau) published in the Federal Register an interim final rule extending compliance dates for its 2023 small business lending rule under the Equal Credit Opportunity Act (Regulation B) (Final Rule) This extension comes in response to court orders in ongoing litigation, affecting the timeline for financial institutions to comply with data collection requirements for women-owned, minority-owned, and small businesses.

On June 12, the U.S. District Court for the Northern District of Illinois denied the joint motion by the Consumer Financial Protection Bureau (CFPB or Bureau) and Townstone Financial, Inc. to vacate the Stipulated Final Judgment and Order previously entered in the CFPB’s enforcement action against the mortgage lender, calling the CFPB’s attempt to refund Townstone’s civil money penalty for alleged redlining practices “breathtaking.” This decision comes after allegations by the current CFPB of misconduct related to the case under former CFPB leadership.

This article was republished in insideARM on June 17, 2025.

On May 22, Illinois House Bill 3352 passed the Illinois legislature and now awaits Governor JB Pritzker’s signature. This bill amends the Illinois Collection Agency Act to provide an individual a way to avoid liability for a coerced debt. HB 3352 defines coerced debt as a debt incurred due to fraud, duress, intimidation, threat, force, coercion, undue influence, or non-consensual use of the debtor’s personal identifying information as a result of domestic abuse, sexual assault, exploitation, or human trafficking.

Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) submitted several regulatory proposals to the Office of Management and Budget (OMB) for review. Among the rules under consideration are those related to loan originator (LO) compensation and discretionary mortgage servicing, governed by the Truth in Lending Act (Regulation Z) and the Real Estate Settlement Procedures Act (Regulation X). Additionally, the CFPB is reviewing its “larger participant” rules, which define the scope of its supervisory authority over major players in the debt collection and consumer credit reporting sectors. These rules, currently in “prerule” status, are under scrutiny by the OMB.