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.
2025 Consumer Litigation Filings: Everything Up Compared to 2024
According to a recent report by WebRecon, court filings under the Fair Credit Reporting Act (FCRA), Fair Debt Collection Practices Act (FDCPA), and Telephone Consumer Protection Act (TCPA), as well as complaints filed with the Consumer Financial Protection Bureau (CFPB) all increased in 2025 compared to 2024. December 2025 filings also rose in every category except TCPA, which declined by only two cases.
Credit Reporting Litigation to Rise Further Given State Laws
Fair Credit Reporting Act litigation continued to increase last year as the industry saw several significant judicial developments.
Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – January 27, 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.
Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – January 21, 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.
California DFPI Considers New Consumer Reporting Registration
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.
HUD Proposes to Rescind Fair Housing Act Disparate Impact Regulations
On January 14, the Department of Housing and Urban Development (HUD) issued a proposed rule that would repeal its Fair Housing Act (FHA or Act) “discriminatory effects” (disparate impact) regulations and leave the development and application of disparate impact standards entirely to the courts. Comments are due February 13, 2026.
Ninth Circuit Holds that Texts Are “Calls” Under the TCPA But Embedded Videos Are Not Recorded Messages
On January 13, the U.S. Court of Appeals for the Ninth Circuit issued a decision in Howard v. Republican National Committee (RNC) offering two important interpretations of the applicability of the Telephone Consumer Protection Act (TCPA) to certain text message communications:
CFPB and DOJ Formally Withdraw 2023 Immigration-Status Fair Lending Guidance
On January 12, the Consumer Financial Protection Bureau and U.S. Department of Justice formally withdrew their October 2023 joint statement on creditors’ consideration of immigration status under the Equal Credit Opportunity Act (ECOA). As we previewed in our December 23, 2025 blog post (available here), the agencies state that the CFPB’s prior statement may have created the misimpression that ECOA or Regulation B impose additional limits on the consideration of immigration or citizenship status beyond the existing regulatory text. The agencies also state that additional guidance on this topic goes beyond Regulation B, so it is unnecessary and appropriate for rescission.
New York Extends CRA Obligations to Nonbank Mortgage Lenders
New York has adopted new regulations, 3 NYCRR Part 120, that will extend New York’s Community Reinvestment Act (CRA) obligations to certain nonbank mortgage lenders operating in the state. Effective July 7, 2026, the rule will require New York State Department of Financial Services (DFS)‑licensed non‑depository mortgage bankers that have originated 200 or more New York State mortgage loans in the prior calendar year to demonstrate that they are providing fair and equitable access to home loans, especially for low‑ and moderate‑income New Yorkers.