The Roundup: FTC Focuses On AI-Generated Endorsements and Affiliate Disclosures,  CFPB Finalizes Reg B and Staff Cut, FTC Settles Ad Collusion, NYC Proposes Click-to-Cancel Rule

Welcome to the PerformLine Regulatory Compliance Roundup, home of the latest news, articles, and reports from our industry, curated for you. Let’s get into it.

In this edition:  FTC Puts AI-Generated Endorsements and Affiliate Disclosures in Its Sights, CFPB finalizes Regulation B overhaul eliminating disparate impact liability; acting director’s workforce plan targets 68% staff reduction; FTC reaches settlements over brand safety collusion; New York City proposes first municipal click-to-cancel rule.

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FTC Puts AI-Generated Endorsements and Affiliate Disclosures in Its Sights

The FTC’s focus on AI-generated content and affiliate marketing disclosures has sharpened considerably heading into 2026. At its Third Conference on Marketing and Public Policy in March, the agency’s agenda included a dedicated research presentation on influencer endorsements and a panel on information disclosure and AI—a clear signal that enforcement is moving beyond consumer-facing influencers and into the operational layer of affiliate programs. 

The core issue for compliance teams is liability scope. The FTC’s guidance makes explicit that brands are accountable when they direct, fund, or benefit from non-compliant endorsements, even when the creator posts independently—and claiming ignorance of a publisher’s disclosure practices is not a viable defense. On the AI front, if the audience cannot reasonably identify that an endorsement was generated or amplified by artificial intelligence, the program is likely in breach of current FTC guidance. In January 2026, the FTC issued its first warning letters under the Consumer Review Rule, citing ten companies for potential violations including the use of fake reviews, incentivized testimonials, and deceptive review practices. Affiverse

Why It Matters: For financial services and performance marketing teams, this enforcement trajectory has direct implications. Any affiliate program using AI tools for content production, automated review generation, or AI-enhanced creator partnerships now carries disclosure risk if those relationships are not clearly surfaced to consumers. The FTC’s shared liability model means that brands—not just publishers—are on the hook when disclosure standards are not met. Compliance teams should audit affiliate contracts and onboarding documentation to confirm they function as compliance instruments, not just commercial agreements, and review any AI-assisted content workflows to verify that both the commercial relationship and the AI’s role are clearly disclosed to audiences.

CFPB Finalizes Regulation B Overhaul, Eliminating 50 Years of Disparate Impact Liability

The Consumer Financial Protection Bureau has finalized a sweeping rewrite of Regulation B under the Equal Credit Opportunity Act, officially removing disparate impact as a basis for federal fair lending enforcement, effective July 21, 2026, and represents the most significant rollback of federal anti-discrimination lending law in nearly five decades.

Under the new rule, the CFPB explicitly states that ECOA “does not authorize disparate impact claims,” meaning lenders can only face federal discrimination liability for intentional acts of bias—not for neutral policies that disproportionately harm protected groups. The rule also narrows the anti-discouragement provision, restricting it to oral, written, or visual statements that a reasonable person would interpret as signaling denial or less favorable terms based on a protected characteristic. Additionally, for-profit lenders are now prohibited from using race, sex, or national origin as criteria for Special Purpose Credit Programs.

Consumer advocates reacted sharply. The National Community Reinvestment Coalition called it “a major step back,” warning it would significantly hamper the ability to prove discrimination, particularly as lenders rely increasingly on algorithmic and AI-driven credit decisions. State attorneys general in California, Massachusetts, New Jersey, and others are expected to maintain disparate impact enforcement under their own statutes, creating a fragmented compliance landscape. American Banker

Why It Matters: Marketing compliance teams must continue monitoring audience targeting and algorithmic decisions for disparate impact because state laws remain enforceable and the five-year statute of limitations creates retroactive liability risk regardless of federal enforcement changes.

Understand your full compliance risk exposure with PerformLine’s Omni-Channel Monitoring

CFPB’s Workforce Restructuring Plan Would Cut Staff by 68%, Reduce Exams by 40%

Acting CFPB Director Russell Vought has filed a Workforce Restructuring Plan in federal court outlining his blueprint for dramatically downsizing the bureau if legal injunctions are lifted. The plan, submitted March 31 as part of the ongoing NTEU v. Vought litigation, would reduce total CFPB staff from approximately 1,723 employees to just 556—a 68% reduction. Supervision staff would fall from 523 to 77, and enforcement attorneys and staff would be cut from 254 to just 50.

The plan also projects a 40% reduction in total examinations: from 107 in 2024 to 64 in 2026, with nonbank exams falling from 61 to 22. Separately, banks and consumer advocacy groups have weighed in on the CFPB’s draft five-year strategic plan, which proposes eliminating nonbank supervision altogether—a move that industry groups say conflicts with Congress’s explicit grant of that authority. Vought has also argued that the bureau’s current funding cap, reduced from 12% to 6.5% of Federal Reserve operating expenses under the One Big Beautiful Bill Act, will leave the agency unable to comply with its injunction by Q4 2026. Consumer Finance Monitor

Why It Matters: As CFPB supervision and enforcement capacity shrinks, state attorneys general are expanding their fair lending and marketing compliance enforcement, requiring marketing compliance teams to strengthen multi-state compliance programs aligned with state-level regulatory priorities.

See how State Regulators are stepping up and how to prepare your compliance teams. Beyond Deregulation: Key Takeaways for Compliance Teams

FTC Reaches Settlements with WPP, Publicis, and Dentsu Over Brand Safety Collusion

The Federal Trade Commission, joined by a coalition of eight state attorneys general, filed suit and simultaneously settled with three of the world’s largest advertising holding companies on April 15. The complaints against WPP (operating as GroupM Worldwide), Publicis, and Dentsu allege that since 2018, the firms unlawfully colluded to establish a common “Brand Safety Floor” through trade associations—specifically the World Federation of Advertisers’ Global Alliance for Responsible Media (GARM) and the American Association of Advertising Agencies’ Advertiser Protection Bureau—that had the effect of directing advertising spend away from certain media platforms.

The FTC characterized the arrangement as unlawful coordination that “distorted the marketplace of ideas” by demonetizing media outlets based on political viewpoints. The companies did not admit or deny wrongdoing but agreed to sweeping behavioral restrictions on how they place digital advertising going forward, along with independent compliance monitors. The district court approved and finalized all three proposed orders. Federal Trade Commission

Why It Matters: Marketing compliance professionals must ensure brand safety standards are determined independently rather than coordinated with competitors or enforced uniformly through industry groups or third-party vendors, as the FTC now scrutinizes such arrangements as antitrust violations.

New York City Proposes First-in-the-Nation Municipal Click-to-Cancel Rule

New York City Mayor Zohran Mamdani and Department of Consumer and Worker Protection (DCWP) Commissioner Samuel Levine announced a proposed “Click-to-Cancel” rule on April 9, opening a 30-day public comment period. If finalized, New York City would become the first municipality in the United States to impose this level of subscription cancellation regulation.

The proposed rule stems from the mayor’s Executive Order 10, “Fighting Subscription Tricks and Traps,” and would require that if a consumer can sign up for a service online, they must be able to cancel it just as easily. The rule targets free trials that convert to paid subscriptions without meaningful consumer awareness, cancellation processes designed to frustrate consumers, and unclear disclosure of subscription terms. Violations carry initial fines of $525 (up to $3,500 for repeat offenses) plus restitution to consumers, and apply to any business marketing subscription services to NYC residents regardless of physical location. The DCWP is accepting public comments through the City Record, with a virtual hearing scheduled for May 8.

The proposal mirrors the FTC’s federal Negative Option Rule, with input from former FTC Bureau of Consumer Protection Director Samuel Levine, now DCWP Commissioner  NYC Mayor’s Office

Why It Matters: Marketing compliance teams must audit all subscription marketing materials to ensure upfront disclosure of terms, pricing, and auto-renewal conditions, remove enrollment friction, and assess financial exposure for any subscriptions marketed to NYC residents, despite business’s physical location.

Monitor your subscription disclosures and marketing claims across all channels with a centralized system to manage disclosures and promotional language to ensure that all marketing materials are compliant before launch. PerformLine’s Automated Pre-Publication Compliance Review 

That’s it for this edition of the Regulatory Compliance Roundup. Have questions, tips, or feedback? Reach out to us at performline.com or connect with us on LinkedIn.