United States: Consumer Credit

Washington, D.C. has enacted comprehensive legislation that fundamentally changes how medical debt is handled, prohibiting healthcare providers and debt collectors from reporting medical debt to credit reporting agencies while imposing strict limitations on collection practices. The law establishes significant protections including wage garnishment restrictions, interest rate caps, and mandatory financial assistance screening, though it faces concerns about potential impacts on the healthcare system's susta

The Federal Trade Commission announced a $12 million settlement with payment processor Humboldt Merchant Services over allegations of facilitating merchant fraud through unauthorized billing scams, while simultaneously rescinding its 2021 policy statement on health app breaches. The settlement imposes permanent restrictions on processing payments for high-risk merchant categories and prohibits credit card laundering activities.

On September 30, the CFPB published a notice seeking comment on a proposed revision to its existing collection of credit card information under the Truth in Lending Act (TILA) and the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act).

New York City's Department of Consumer and Worker Protection has issued comprehensive guidance on its SHIELD Rule through a detailed FAQ, clarifying how the sweeping debt collection regulations will operate when they take effect January 1, 2027. The guidance addresses critical operational questions about contact limits, dispute procedures, verification requirements, and special protections for medical debt that go substantially beyond federal requirements. Companies collecting debts from New York City consu

New York's Department of Financial Services has issued a proposed rule implementing the state's Buy-Now, Pay-Later Act, introducing significant new obligations for BNPL lenders including interface requirements, disclosure mandates, and interest rate caps. The rule narrows some previously proposed requirements while adding new compliance burdens that could affect consumer financing programs far beyond traditional pay-in-four products.

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New York's Department of Financial Services has proposed comprehensive regulations establishing a licensing and regulatory framework for buy now, pay later lending in the state. The proposed rules impose extensive requirements covering underwriting, disclosures, fees, disputes, data use, and customer service, while creating a state-by-state compliance patchwork as federal oversight recedes. BNPL providers may need to significantly modify their operations, including underwriting processes, payment flows, and

Banking Agencies Issue Interagency Guidance On Lending To Non-Work Authorized Borrowers

The Tenth Circuit's en banc review of National Association of Industrial Bankers v. Weiser examines whether Colorado can use federal law to prevent out-of-state banks from exporting interest rates to Colorado borrowers. The Bell Policy Center's amicus brief argues that bank-fintech partnerships have undermined Colorado's consumer protection efforts and that expensive true lender litigation is inadequate to address high-cost lending. At stake is the interpretation of Section 525 of DIDMCA and whether state l