In a significant development for lenders and borrowers alike, on October 6, the U.S. Supreme Court declined to review the Fox decision, leaving unresolved questions about the retroactive application of the Foreclosure Abuse Prevention Act (FAPA). This decision has shifted the focus to the New York State Court of Appeals where oral argument was heard on October 16, and potentially to the U.S. Court of Appeals for the Second Circuit.
A federal appeals court has rejected the Trump Administration’s request to delay its response to an en banc hearing request in the lawsuit challenging the mass firings at the CFPB due to the government shutdown.
On October 13, 2025, Governor Gavin Newsom enacted Assembly Bill No. 692 (AB 692), effectively adding Section 16608 to the Business and Professions Code and Section 926 to the Labor Code.
Working with debt settlement firms is no longer a fringe recovery strategy. For many lenders, it now accounts for a meaningful portion of post-charge-off resolution—and demands infrastructure and automation that can keep up with its pace, complexity, and oversight requirements.
On October 14, the Maryland Office of Financial Regulation (OFR) issued regulatory guidance explaining three new state laws governing the collection and reporting of medical debt. The guidance clarifies how House Bills 428, 1020, and 268, all effective October 1, 2025, alter the obligations of hospitals, debt collectors, and consumer reporting agencies.
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