On October 11, the Office of Administrative Law (OAL) approved the California Department of Financial Protection and Innovation’s (DFPI) proposed regulations on direct-to-consumer (i.e., non-employer offered) earned wage access (EWA) products. This approval marks the culmination of a lengthy regulatory process that began in March 2023 and involved multiple rounds of modifications and public comments. The regulations also impose requirements on debt settlement companies and education financing providers. It will become effective on February 15, 2025.
Yesterday, we discussed the constitutional legal challenge against New York City’s recently amended debt collection rules, which were scheduled to go into effect on December 1, 2024. These rules would stringently regulate various debt collection activities by debt collectors operating in the city. Today, the New York City Department of Consumer and Worker Protection (DCWP) announced a delay in the enforcement of these new rules until April 1, 2025.
On October 16, the FTC issued its final amendments to the Negative Option Rule, which now applies to all negative option programs and includes a “click to cancel” provision intended to make it easier for consumers to cancel their enrollment in order to halt continued charges.
Beginning in February 2025, the DFPI will register and regulate debt settlement services, education financing, income-based advances, and student debt relief providers – all to protect California consumers and provide more transparency.
The Office of the Comptroller of the Currency (OCC) is revising its guidelines establishing standards for recovery planning by certain large insured national banks, federal savings associations, and federal branches at 12 CFR 30, appendix E/ The final guidelines are effective on January 1, 2025, with staggered compliance dates.
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