In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso lay out a practical set of 2026 resolutions for dealers and auto finance companies. Chris breaks down why state law compliance should be at the top of your list, from California’s CARS rule and junk fee laws to new disclosure and renewal requirements cropping up across the country. Brooke then shifts to the federal landscape, focusing on the Fed’s recent rate cuts, what a lower-rate environment could mean for auto loan refinancing, and the compliance risks that come with more paperwork. The discussion also tackles the real-world impact of AI — how consumers are using it in disputes and litigation, and how companies must carefully govern their own AI tools, including chatbots. Finally, they underscore the importance of a robust consumer complaint process as an early-warning system and a powerful tool to prevent small issues from turning into lawsuits.

The National Credit Union Administration (NCUA) has submitted a proposed rule to the Office of Management and Budget (OMB) to implement the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. The proposal is not yet public. Once OMB completes its review, the rule will be published in the Federal Register with a public comment period.

On December 19, New York Governor Kathy Hochul signed Senate Bill S1353A creating a new General Business Law article on “actions involving coerced debts.” The law is aimed squarely at survivors of domestic violence, trafficking, and other forms of economic abuse who find themselves saddled with credit card balances, loans, or other consumer debts they never truly agreed to incur. Once effective (90 days after signing), it will prohibit creditors from enforcing certain coerced consumer debts against victims, create a structured process for disputing those debts, and establish robust private rights of action and defenses against collection. New York becomes the eighth state to enact protections of this kind.

On December 12, Wisconsin legislators introduced Senate Bill 759 (SB 759), which would substantially shift Wisconsin’s approach to consumer lending. The bill would:

  • Impose a 36% annual percentage rate (APR) cap on consumer loans made by licensed lenders;
  • Adopt predominant economic interest and totality of the circumstances tests that expand which entities “make” loans under the law and are subject to licensing;
  • Add broad anti‑evasion language; and
  • Require new, detailed reporting from licensed lenders to the Division of Banking within the Department of Financial Institutions (DFI).

As reported by Bloomberg here, the Consumer Financial Protection Bureau (CFPB or Bureau) is moving to withdraw a 2023 Biden-era joint statement with the U.S. Department of Justice (DOJ) that warned lenders against overbroad use of immigration status in credit decisions. The notice, submitted to the White House’s Office of Information and Regulatory Affairs (OIRA), ties together two hallmark priorities of the current Trump administration: a harder line on immigration and a continued effort to scale back fair lending enforcement. While the underlying Equal Credit Opportunity Act (ECOA) remains unchanged, the move signals a sharp shift in how the CFPB and DOJ are likely to interpret and enforce its protections for noncitizen borrowers.

The Consumer Financial Protection Bureau (CFPB or Bureau) released a new market “data spotlight” on Buy Now, Pay Later (BNPL) that uses actual transaction data from six large providers of “pay-in-four” BNPL loans. The report paints a picture of growing adoption paired with improving credit performance: late fees fell and charge-off rates declined in 2023, even as the number of loans and users rose.

On December 17, New Jersey announced its adoption of what its Attorney General is calling the “most comprehensive state-level disparate impact regulations in the country.” Effective December 15, 2025, the Division on Civil Rights’ (DCR) new rules under the New Jersey Law Against Discrimination (LAD) codify guidance on disparate impact discrimination across housing, lending, employment, places of public accommodation, and contracting.

As we discussed in our prior post on National Treasury Employees Union (NTEU) v. Consumer Financial Protection Bureau (CFPB or Bureau), on August 15 the U.S. Court of Appeals for the District of Columbia issued a decision vacating the district court’s preliminary injunction, which had previously restricted the CFPB’s actions to halt the Bureau’s operations and terminate its employees. The court of appeals held that most of the employees’ claims belonged in the Civil Service Reform Act regime and that the remaining claims did not target reviewable final agency action or equitable claims.

In this episode of The Consumer Finance Podcast, host Chris Willis is joined by Troutman Pepper Locke Partner Lori Sommerfield and Charles River Associates VP and Practice Leader of Financial Economics Marsha Courchane to discuss the current administration’s “debanking” initiative established through Executive Order 14331. They discuss key actions taken by federal agencies to implement it, expectations for financial institutions and small business lenders to conduct internal reviews, regulatory reporting deadlines, and consequences for noncompliance. This episode also features practical tips on tools and technology that institutions/small business lenders can use to facilitate conducting debanking reviews and highlights the tension between the debanking initiative and financial institutions’ need to comply with the Bank Secrecy Act and other federal anti-money laundering laws.