In her December 30, 2025 opinion in National Treasury Employees Union v. Vought (which we blogged about here), Judge Amy Berman Jackson concluded that the CFPB may continue to draw funding from the Federal Reserve System even when the Federal Reserve, on a combined basis, is losing money. According to the court, the statutory phrase “combined earnings of the Federal Reserve System” in 12 U.S.C. § 5497(a)(1) means all revenue earned by the Federal Reserve, not profits, and therefore permits CFPB funding even during periods when the Federal Reserve’s expenses exceed its income.
New York has enacted new consumer protections related to coerced debt following Gov. Kathy Hochul’s signing of Senate Bill S1353B on Dec. 19, 2025. The law establishes restrictions on the enforcement of certain consumer debts and outlines new legal remedies for affected individuals.
In a case of first impression, in clarifying her injunction issued in the lawsuit brought by the National Treasury Employees Union and others challenging the planned reductions in force and other efforts to reduce functions at the CFPB, Judge Amy Berman Jackson of the DC Federal District Court vigorously rejected the opinion of the Office of Legal Counsel of the Department of Justice (“OLC”) that the CFPB may not be funded by the Fed because (1) the Dodd-Frank Act provides that the CFPB may only be funded by the Fed out of “combined earnings of the Federal Reserve System”, (2) the term “combined earnings” means combined profits and not combined revenues and (3) the Federal Reserve System has incurred losses since September 2022.
Everything Dropped in November
Nov 2025 was one of those slower months resulting in a lot of red on the board for us when compared to the previous month’s numbers. But with the exception of TCPA, everything was actually up from last year. And in the case of TCPA, it is only down (nominally) from last year (and for the YTD) because Nov 2024 was so extraordinary with over 1000 TCPA plaintiffs in that month alone.
The Federal Deposit Insurance Corporation (FDIC) today issued its list of state nonmember banks recently evaluated for compliance with the Community Reinvestment Act (CRA). The list covers evaluation ratings that the FDIC assigned to institutions in October 2025.
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