On August 6, 2025, in Corner Post, Inc. v Board of Governors of the Federal Reserve System, the U.S. District Court for the District of North Dakota (the “Court”) granted Corner Post’s motion for summary judgment, finding that the Federal Reserve Board (the “Board”) exceeded its authority in adopting Regulation II, which in part caps debit card interchange fees. The Court held that the Board exceeded its authority by including the “third category” of costs that were specific to a particular transaction but were not incremental costs incurred by an issuer for the role of the issuer in the authorization, clearance, or settlement of a particular electronic debit transaction.
On August 8, the CFPB published four advance notices of proposed rulemaking in the Federal Register seeking public comment to reconsider the test for defining larger participants in the consumer reporting, debt collection, international money transfer, and automobile financing markets.
On July 28, the New Jersey Division of Consumer Affairs issued a reminder to more than 3,000 auto dealerships regarding their obligations under the New Jersey data deletion law, N.J.S.A. § 56:12-18.1. This law, enacted and effective in January 2024, requires dealerships to offer data deletion services for consumer information stored in vehicles accepted for resale or lease. Dealerships are now on notice of their compliance obligations under the law.
Collection departments can’t afford to focus on just one data point or a single month’s performance. To understand what’s really coming down the pike, you have to step back and see the entire landscape — and right now, that landscape has some dark clouds forming.
The Federal Reserve Bank of New York’s Q2 Household Debt and Credit Report just landed, and buried inside is a warning sign. Credit card delinquencies — accounts 90+ days past due — are inching dangerously close to the levels we saw during the 2008–2009 financial crisis.
President Trump has issued an Executive Order directing banking agencies to adopt policies to ensure that financial institutions do not use reputational risk as a basis for restricting access to banking services—a process known as “debanking.”
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