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October

9
2025
Compliance

Controversial NYC Debt Collector Rules On Hold Indefinitely, While New Rules Loom

The pressure is off for collectors of debts owed by New Yorkers for now, under a New York City regulation that has been years in the making, and which has already seen its effective date postponed twice before. The New York City Department of Consumer and Worker Protection (DCWP) has announced that the effective date of its expansive new regulations—which were finally set to take effect October 1—have been postponed indefinitely.

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October

9
2025
Industry News

California’s CARS Act Signed into Law

On October 6, Governor Gavin Newsom signed into law the California Combating Auto Retail Scams (CARS) Act. This legislation aims to fortify consumer protections and enhance transparency in the car-buying process. The enactment of this law follows a series of discussions and amendments, as highlighted in our previous blog and podcast, which traced the bill’s evolution and its alignment with the Federal Trade Commission’s (FTC) vacated CARS Rule.

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October

8
2025
Industry News

Stressing urgency, fired NCUA Democratic board members ask Supreme Court to consider case on expedited basis

The two Democratic NCUA board members ousted by President Trump without cause are asking the Supreme Court to consider their challenge of the firings on an expedited basis.

Todd Harper and Tanya Otsuka are challenging their firings even though the Federal Credit Union Act, unlike some federal laws governing other financial regulators, does not state that members of the agency board may only be removed for cause.

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October

8
2025
Industry News

Agencies Issue Proposal to Focus Supervision on Material Financial Risks

The Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (the agencies) today issued a joint notice of proposed rulemaking that would continue their effort to focus supervision on material financial risks. Among other things, the proposal would define the term “unsafe or unsound practice” for purposes of section 8 of the Federal Deposit Insurance Act and revise the supervisory framework for the issuance of matters requiring attention (MRAs) and other supervisory communications.

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October

8
2025
Industry News

Prohibition on Use of Reputation Risk by Regulators: Notice of Proposed Rulemaking

The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) are issuing a notice of proposed rulemaking to codify the elimination of reputation risk from their supervisory programs. Among other things, the proposed rule would prohibit the agencies from criticizing or taking adverse action against an institution on the basis of reputation risk.

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