On May 19, Virginia Governor Abigail Spanberger (D) indicated that she intends to veto SB 229, a pending bill which would have created a Virginia state court class action mechanism and would have modified the Virginia Consumer Protection Act (VCPA) in critical ways. Governor Spanberger initially noted that she “approve[d] the general purpose of this bill,” but returned it to the legislature with proposed amendments.
On May 15, the Office of the Comptroller of the Currency (OCC) finalized two closely linked rules on mortgage escrow accounts that respond directly to the issues we discussed in our recent post, Second Circuit on Remand in Cantero: New York Escrow-Interest Law Is Preempted, Over a Vigorous Dissent. In that decision, the Second Circuit held that New York’s 2% interest‑on‑escrow statute is preempted as applied to national banks under the Barnett Bank standard, deepening a circuit split with the First and Ninth Circuits. The OCC’s new rules both adopt the Second Circuit’s view of the underlying bank powers and attempt to bring regulatory clarity to the interest‑on‑escrow preemption question for OCC‑regulated institutions nationwide.
Marking the latest development in the trend toward increased regulation of automatically renewing subscription offers, on April 8, the New York City Department of Consumer and Worker Protection (DCWP) proposed what would be the nation’s first municipal “Click to Cancel” rule. This proposed regulation would mirror existing state law requirements providing for consumer rights and protections concerning automatic renewal or continuous service offers. In doing so, the DCWP takes aim at so-called “subscription traps” that it claims unfairly prevent consumers from discontinuing services they no longer wish to pay for. Specifically, the rule would make failure to offer consumers streamlined cancellation methods for continuous service offers a deceptive and unconscionable practice in violation of the New York City Administrative Code. This proposal marks the latest development in New York City’s efforts to prioritize consumer protection initiatives across economic sectors. Important elements of the proposed rule are summarized below.
On April 28, Governor Wes Moore (D) signed Senate Bill 94 into law, significantly revising Maryland’s earned wage access (EWA) framework and tightening restrictions on tipping practices in both EWA programs and certain consumer loans. The new law amends multiple provisions of the Commercial Law Article and adds new sections governing advertising, anti‑discrimination, and regulatory safe harbors.
Delaware is positioning itself at the center of digital asset and stablecoin innovation with a coordinated package of legislation aimed at modernizing its banking code and creating a comprehensive framework for payment stablecoins. Senate Bill 16, the “Delaware Banking Modernization Act of 2026,” (SB 16) and Senate Bill 19, the “Delaware Payment Stablecoin Act,” (SB 19) were introduced on March 23, 2026, and are currently moving through the General Assembly. If enacted, both measures would take effect immediately, with implementation required by the earlier of one year after enactment or the issuance of final regulations by the State Bank Commissioner.
As reported by Law360, the U.S. Department of Justice (DOJ) has decided to move forward with its $68 million settlement with Colony Ridge Development LLC without seeking court approval or ongoing judicial oversight. The settlement at issue (discussed here) resolves DOJ and Texas reverse redlining and predatory lending claims in exchange for extensive operational reforms and $48 million in infrastructure improvements plus $20 million in law enforcement and public-safety spending, but no civil money penalties or direct monetary relief to borrowers.
On April 3, Kentucky enacted SB 158, a comprehensive statute governing products that offer benefits in connection with personal property, with a particular focus on add‑on products sold with vehicle finance and lease transactions. The law creates a formal regulatory framework for “vehicle financial protection products,” provides that they are not “insurance”, and ties compliance to the state’s retail installment and consumer loan regimes. Most vehicle financial protection provisions apply to products that become effective on or after January 1, 2027.
The Federal Trade Commission (FTC) has taken a highly visible step into the national debate over “debanking” by sending warning letters to several large payment networks and financial services providers, reminding them that deplatforming or denying customers access to financial products or services due to political or religious beliefs could violate their existing obligations under Section 5 of the FTC Act. The FTC’s letters signal a sharpened enforcement focus on how financial services firms manage account closures, suspensions, and access to services, particularly when political or religious views are implicated.
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) were all up compared to January 2025. Compared to December 2025, however, the results are mixed.
In December 2023, we blogged about lawsuits filed by the Consumer Financial Protection Bureau (CFPB or Bureau), the U.S. Department of Justice (DOJ), and later the State of Texas against Colony Ridge and related entities. The complaints alleged that Colony Ridge targeted Hispanic borrowers with deceptive Spanish‑language marketing, sold largely undeveloped and flood‑prone land, and engaged in predatory financing by steering borrowers into high‑rate, seller‑financed mortgage loans with extremely high foreclosure rates.