State Attorneys General

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Louisiana and Massachusetts have each recently issued guidance addressing motor vehicle dealer advertising practices, particularly around the disclosure of fees in advertised vehicle prices. Both actions follow the Federal Trade Commission’s March 13, 2026 “Notorious 97” warning letters to auto dealership groups nationwide (discussed here) and reflect ongoing efforts at the state and federal level to ensure that advertised prices accurately reflect the total cost consumers will be required to pay.

The New York City Department of Consumer and Worker Protection (DCWP) recently published new compliance resources for its amended debt collection regulations, known as the SHIELD Rule, which are scheduled to take effect on September 1, 2026.

On June 16, Vermont Governor Phil Scott signed H.648, a wide‑ranging financial services bill that, among other changes, brings sales‑based financing and certain factoring arrangements squarely within the state’s regulated financial services framework. The sales‑based financing provisions were added late in the process, borrowing heavily from the most controversial elements of Texas’s 2025 HB 700 (discussed here) and other state commercial financing disclosure laws, and layering Vermont‑specific requirements on top of existing licensed lender rules. The commercial financing portions of the law are to take effect July 1, 2027.

On June 2, Louisiana Governor Jeff Landry signed SB 254 into law as Act 751, prohibiting retail businesses from imposing surcharges on customers who pay with a debit card. The law takes effect August 1, 2026.

Virginia is implementing a new Business Screening Services (BSS) program that will significantly change how private background screening companies handle Virginia criminal and traffic history records.

On April 8, Virginia Governor Abigail Spanberger signed HB 444, the Uniform Consumer Debt Default Judgments Act, into law. The Act establishes pleading and notice requirements in certain consumer debt collection actions that must be met for a creditor to obtain a default judgment against a consumer. This Act is based on a model drafted by the Uniform Law Commission, similar versions of which have been enacted in Washington and introduced in Pennsylvania. HB 444 will take effect on July 1, 2027.

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 May 12, the Colorado legislature passed Senate Bill 26‑189, a substantial rewrite of its 2024 law establishing consumer protections for artificial intelligence (formerly referred to as the CO AI Act), and replaced it with a more targeted framework for “automated decision‑making technology” (ADMT). The changes will take effect on January 1, 2027.