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January

14
2026
Industry News

FTC Asks Court to Hold Payment Processors in Contempt for Systematically Violating 2015 Order

The Federal Trade Commission has asked a federal court to hold the operators of a payment processing operation in contempt for systematically violating their 2015 order with the agency over allegations they illegally processed credit card payments.

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January

14
2026
Trends

CFPB Releases Seventh Biennial Review of the U.S. Credit Card Market

The Consumer Financial Protection Bureau (CFPB) has published its seventh biennial review of the consumer credit card market, as required under the Credit Card Accountability Responsibility and Disclosure (CARD) Act of 2009. The report examines how credit cards are used, how issuers operate, and how the market has evolved, drawing on data through 2024.

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January

13
2026
Compliance

Portion of TCPA Global Revocation Rules Further Extended – Now Effective January 2027

The Consumer and Governmental Affairs Bureau (“CBG”) has extended, to January 31, 2027, the effective date of the Federal Communications Commission’s (“FCC”) Telephone Consumer Protection Act (“TCPA”) “global revocation” rule.[i]

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January

13
2026
Industry News

CFPB and DOJ withdraw joint statement on consideration of immigration status under ECOA

As previously reported, in October 2023 the CFPB and DOJ issued a joint statement regarding “the potential civil rights implications of a creditor’s consideration of an individual’s immigration status under the Equal Credit Opportunity Act (ECOA).”

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January

13
2026
Industry News

CFPB issues advisory opinion on the applicability of Regulation Z to earned wage access products

On December 23, the CFPB issued an advisory opinion in the Federal Register clarifying the regulatory treatment of earned wage access (EWA) products under Regulation Z, as implemented by TILA. The advisory opinion stated that certain EWA products, referred to as “Covered EWA,” do not constitute credit under Regulation Z, provided they meet four key criteria: (i) advances are limited to wages already earned and verified by payroll records; (ii) payment occurs exclusively through the employer’s payroll process instead of direct account withdrawals; (iii) providers give clear notice that they will not pursue debt collection, credit reporting, or seek payment from personal accounts if payroll deductions are insufficient; and (iv) providers do not assess individual workers’ creditworthiness. The CFPB emphasized that these products function more like early wage payments rather than extensions of credit, as workers are simply accessing funds they have already earned.

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