On September 8, the Department of Labor’s Employee Benefits Security Administration (EBSA) issued Field Assistance Bulletin No. 2026-03, outlining how it will enforce the Mental Health Parity and Addiction Equity Act’s (MHPAEA) nonquantitative treatment limitation (NQTL) requirements going forward. The bulletin follows through on EBSA’s January 2026 announcement identifying mental health/substance use disorder (MH/SUD) benefit barriers as a national enforcement priority, and responds to sustained industry complaints that prior NQTL enforcement and comparative analyses requirements created confusion and unnecessary compliance burdens.

On September 9, the Federal Communications Commission (FCC) released a Report and Order and Further Notice of Proposed Rulemaking (FNPRM) (FCC-CIRC 2609-05) substantially revising the consent-revocation rules that were set to take effect January 31, 2027 under the Telephone Consumer Protection Act (TCPA). The new rules take effect just 30 days after Federal Register publication, superseding that delayed date entirely, so businesses have far less runway than expected.

In this episode of the “Point-of-Sale Finance” series, Jason Cover is joined by colleagues Erin Edwards and Simon Fleischmann from Troutman Pepper Locke’s Consumer Financial Services practice to shift the lens from regulatory compliance to litigation risk. The conversation broadens the frame beyond Buy Now, Pay Later (BNPL) to the full point-of-sale credit ecosystem (Pay in 4 products, embedded installment loans, retail installment sales contracts, and private label retail cards), explaining why litigation risk turns less on how a product is marketed and more on what the consumer saw, what they were told, and what happened when something went wrong after checkout.

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To keep you informed of recent activities, below are several of the most significant federal events that have influenced the Consumer Financial Services industry over the past week.

Federal Activities

State Activities

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso break down California’s CARS Act, set to take effect October 1. They trace the law’s roots back to the FTC’s now-overturned CARS Rule, walk through its four core compliance pillars (misrepresentations, total price disclosures, valueless add-ons, and recordkeeping), and dig into the new three-day right to cancel for used vehicles. The hosts also cover enforcement risk under California’s UCL and CLRA, the exposure lenders face through the Holder Rule, and five practical steps dealers and their partners should be taking right now to get ahead of the law’s arrival.

The Federal Trade Commission (FTC) has entered into a stipulated order for permanent injunction against 5967 Ventures, LLC, doing business as Humboldt Merchant Services, resolving allegations that the payment processor facilitated fraud by opening and maintaining payment processing accounts for shell companies and merchants engaged in deceptive practices. The order, filed on September 8 in the U.S. District Court for the Eastern District of Michigan, carries significant implications for the payment processing industry.

As we reported in December 2025, New Jersey’s Division on Civil Rights (DCR) adopted what its Attorney General described as the “most comprehensive state-level disparate impact regulations in the country” under the New Jersey Law Against Discrimination (LAD). Those rules, effective December 15, 2025, codify a broad burden-shifting framework for disparate impact claims across housing, lending, employment, public accommodations, and contracting, and include specific guidance on liability arising from the use of artificial intelligence and automated decision-making tools. Now, the Mortgage Bankers Association (MBA) has filed suit to stop them.

In this episode of The Consumer Finance Podcast, host Chris Willis is joined by colleague Kim Phan to break down the proposed regulations recently released by the Colorado attorney general (AG) under the Automated Decision-Making Technology (ADMT) Act, Colorado’s newly amended AI statute, and explain why the financial services industry needs to engage before these rules are finalized.

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To keep receiving your weekly insights, all you need to do is subscribe to our new Consumer Financial Services Weekly Newsletter — it’s quick and easy.

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To keep you informed of recent activities, below are several of the most significant federal events that have influenced the Consumer Financial Services industry over the past week.

Federal Activities

State Activities

International Activities

In a significant en banc decision issued on August 11, 2026, the U.S. Court of Appeals for the Fifth Circuit largely affirmed a district court ruling that invalidated key portions of the federal agencies’ rules governing the calculation of the “qualifying payment amount” (QPA) under the No Surprises Act (NSA). The court’s decision has major implications for how insurers calculate the benchmark rate at the center of the NSA’s independent dispute resolution (IDR) process.