Welcome to Hudson Cook Insights - a collection of articles written each month by the attorneys of Hudson Cook, LLP, in an effort to keep their clients and other compliance professionals informed about current trends and developments in consumer credit finance that will affect the way they do business.
For those interested in all things "Interest" related, we provide a summary of recent state and federal court cases involving usury, finance charges, and interest rates, as they relate to the consumer and commercial credit industries. Assuming the courts stay busy, please look for our next edition towards the end of winter. article continued
In mid-December New York joined a growing number of states that regulate coerced debt. The law, found in a new Article of the New York General Business Laws, will become effective on March 20th. Without question, coerced debt laws serve a noble purpose. However, even upon its passage New York Governor Kathy Hochul noted in her Approval Memorandum that the legislation "contains numerous technical errors, substantive issues and structural defects" that are to be addressed in the 2026 legislative session. Pending such corrections, what should creditors do? article continued
Throughout 2025, Hudson Cook's Consumer Financial Services Bites of the Month webinar program tracked and presented key regulatory, enforcement, and policy developments across the consumer finance landscape. From CFPB and FTC enforcement actions to rulemaking, litigation, and supervisory priorities, each monthly "bite" highlighted issues with real operational and compliance impact. article continued
On November 13, the Consumer Financial Protection Bureau published a Notice of Proposed Rulemaking proposing various revisions to Regulation B. These revisions would impact whether disparate impact is a cognizable legal theory under the Equal Credit Opportunity Act, under what circumstances a creditor may be deemed to be discouraging an applicant or prospective applicant, and under what conditions a creditor may offer special purpose credit programs (SPCPs). article continued
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