On September 15, Oregon Governor Tina Kotek signed into law House Bill 3178, introducing new requirements for auto dealers in the state. This legislation aims to standardize certain aspects of auto finance transactions, specifically those involving retail installment contracts (RICs) or lease agreements, and ensure clarity in the car-buying process. The law will take effect in 2026.
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week.
On September 19, the U.S. Department of the Treasury issued an Advance Notice of Proposed Rulemaking (ANPRM) seeking public input on the implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. This ANPRM builds upon the Request for Comment on Innovative Methods to Detect Illicit Activity Involving Digital Assets issued by Treasury on August 18, which remains open for comment until October 17, 2025.
Key point: Plaintiffs’ attorneys have started sending a wave of letters asserting opt-out and access rights under California’s Shine the Light law.
Over the last three months, businesses have been receiving requests from California residents seeking to exercise their rights under California’s Shine the Light law, Cal. Civ. Code § 1798.83. These requests are sent by attorneys who purport to represent a California resident who is a “customer” of, and has an “established business relationship” with, the business receiving the request. The requests seek an accounting of the customer’s personal information disclosed to third parties for direct marketing purposes within the past year.
On September 15, the Court of Appeals of the State of Washington reversed a lower court’s decision in Aaland v. CRST Home Solutions, LLC (CRST), holding that unsolicited text messages sent to recruit independent contractors qualified as “commercial” messages under the state’s Commercial Electronic Mail Act (CEMA). The decision vastly expands the scope of the state statute.
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week.
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week.
The Federal Communication Commission (FCC) has finalized its rule under the Telephone Consumer Protection Act (TCPA), addressing prior express consent requirements for sellers to send advertisements and telemarketing notices using an automatic telephone dialing system (ATDS) or artificial/prerecorded voice. Notably, the one-to-one requirement has been removed.
On August 29, the Federal Deposit Insurance Corporation (FDIC) announced updates to its Consumer Compliance Examination Manual, marking a pivotal shift in how potential discrimination under the Equal Credit Opportunity Act and Fair Housing Act will be evaluated. The FDIC will now focus solely on evidence of disparate treatment, removing all references to disparate impact analysis from its examination procedures. This action follows on the heels of the OCC’s announcement on July 14 that it had removed all references to disparate impact analysis from the Fair Lending booklet of the Comptroller’s Handbook and directed examiners to cease examining banks for disparate impact liability, discussed here.
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week.