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On February 23, the New York Department of Financial Services (DFS) issued a proposed new Part 423 to Title 3 of the NYCRR to implement New York Banking Law Article 14‑B for Buy-Now-Pay-Later (BNPL) lenders. The proposal would move BNPL firmly into New York’s credit system, imposing licensing, supervision, disclosure, data privacy, and underwriting requirements on both interest‑free and interest‑bearing BNPL products offered to New York consumers. If adopted, the rule would take effect 180 days after the notice of adoption is published in the State Register, with a short transitional period for existing BNPL providers. DFS is accepting pre-proposal comments through March 5, 2026, after which the proposed rule will be published in the New York state register for a formal 60-day comment period.

On February 24, the New Jersey State Senate unanimously confirmed the appointment of Jennifer Davenport to serve as New Jersey’s attorney general (AG). Davenport (whose nomination we covered here) has been serving in an acting capacity since Governor Mikie Sherrill took office in January.

In this special crossover episode of Regulatory Oversight and FCRA Focus, Kim Phan is joined by Michael Yaghi, partner in Troutman Pepper Locke’s Regulatory Investigations, Strategy + Enforcement practice group, to unpack the California Department of Financial Protection and Innovation’s (DFPI) latest effort to require registration for the credit reporting industry. They discuss DFPI’s second request for comment, how it fits into California’s broader push to regulate nonbank financial services, and which entities may be swept in beyond the “big three” consumer reporting agencies — such as furnishers, data brokers, specialty credit reporting agencies, resellers, and fintechs. Kim and Michael also explore how narrowly (or broadly) the rules might be drawn, potential overlap and tension with existing FCRA requirements, what registration and reporting could mean in practice for covered entities, and what companies should be doing now as the February 26 comment deadline approaches.

On March 6, 2026, a U.S. district court will consider whether to approve a settlement agreement resolving parallel lawsuits by the Texas attorney general (AG) and the federal government against Houston-area developer Colony Ridge Development, LLC and related companies. The complaints in both suits — which were filed during the Biden administration — claim that Colony Ridge discriminatorily targeted Hispanic consumers with predatory financing to purchase land for residences in areas that were in fact uninhabitable.

In this special crossover episode of Regulatory Oversight and The Consumer Finance Podcast, Chris Willis is joined by colleagues Lori Sommerfield and Matthew Berns to discuss New Jersey’s sweeping new disparate impact regulations under the Law Against Discrimination. They break down one of the most comprehensive state-level disparate impact rules in the U.S., the contrasts with traditional federal standards, and implications for enforcement in financial services. The discussion dives into credit scores, underwriting models, AI and automated decision-making tools, and the difference between New Jersey’s approach and the Trump administration’s effort to scale back disparate impact at the federal level, offering practical takeaways for lenders and other covered entities navigating this shifting landscape.

In this episode of Moving the Metal, hosts Brooke Conkle and Chris Capurso are joined by Troutman colleagues Chris Carlson and Nam Kang from the firm’s RISE Practice Group to unpack what “Trump 2.0” really means for dealers and auto finance companies. With the Consumer Financial Protection Bureau (CFPB) and other federal regulators pulling back, the group explains how state attorneys general (AGs) and state financial regulators are rapidly filling the void — often led by former CFPB staff now embedded in state offices — and why that creates a complex patchwork of unfair or deceptive acts or practices standards and enforcement approaches across 50 states. They discuss hot-button themes like affordability, junk fees, mini-CFPBs, and the growing role of state working groups, as well as how state AGs are leveraging prior CFPB theories, the California CARS rule, and copy‑and‑paste complaints.

This article was originally published on Law360 and is republished here with permission as it originally appeared on January 22, 2026.

Since the change in administration last year, much has changed in the payments law landscape. Federal regulators have been busy rescinding agency guidance, advisory opinions, interpretive rules and policy statements.

State attorneys general (AGs) are among the most active and influential regulators in the U.S., using broad statutory authority, political visibility, and growing technical knowledge to shape policy and enforcement across sectors. In 2025, they asserted their authority to shape the legal and regulatory environment across the U.S. through aggressive and coordinated action. Despite changing…