The Roundup: The CFPB’s Deregulatory Agenda Advances as Its Leadership Fight Pauses, FTC “Made in USA” Enforcement, State Junk-Fee Laws, and CT’s Click-to-Cancel Law Takes Effect

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: the CFPB releases a deregulatory 2026 agenda, rescinds its Special Purpose Credit Program advisory opinion, and pauses its mass-firing litigation pending the Senate confirmation of a permanent director; the FTC intensifies “Made in USA” enforcement; state pricing-transparency and junk-fee laws continue to expand; a look at the CFPB’s returning open banking rule; plus Connecticut’s amended click-to-cancel law takes effect as states step up on subscription protections.

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CFPB’s Deregulatory Agenda Advances as Its Leadership Fight Pauses

The CFPB kept its deregulatory shift moving in June and July, even as its own future stays unresolved. The Bureau’s revised ECOA/Regulation B rule, which effectively eliminates disparate impact as a theory of liability under ECOA, took effect July 21. On June 17, the Bureau rescinded a 2020 advisory opinion on Special Purpose Credit Programs to align with the new rule: for-profit SPCPs can no longer use race, color, national origin, or sex as eligibility criteria, and programs must show they serve applicants who would actually be denied credit, not just those who might be. On July 6, the CFPB released its 2026 regulatory agenda, confirming more deregulatory rulemaking ahead despite a sharply reduced staff.

On the leadership front, the mass-firing litigation is on hold. On July 10, Judge Amy Berman Jackson granted a joint stay request, pausing the reduction-in-force case until 60 days after the Senate confirms or rejects Brian Johnson, Trump’s nominee for permanent director and a current Capital One executive. Johnson’s confirmation hearing took place July 23; he pledged to recuse himself from Capital One matters for two years if confirmed.  Consumer Financial Services Law Monitor

Why It Matters: The through-line across recent editions holds: a smaller, less active CFPB is still reshaping the rules of the road through deregulation, even with limited staff. For lenders, the SPCP change and the now-effective disparate impact rule together narrow federal fair lending exposure—but state statutes and regulators, including New York’s DFS and California’s DFPI, continue to enforce disparate impact and fair lending standards independently. The leadership stay means the Bureau’s ultimate size and enforcement posture won’t be settled until Johnson’s confirmation plays out, so plan for continued uncertainty and a multi-state enforcement environment.

FTC Marks “Made in the USA Month” With a Renewed Crackdown on U.S.-Origin Claims

The FTC intensified its “Made in USA” enforcement in July, following the Trump administration’s March 13 executive order directing the agency to prioritize enforcement against deceptive “Made in America” claims. FTC Chairman Andrew Ferguson designated July as “Made in the USA month,” and the agency marked the period—coinciding with the nation’s 250th anniversary—with new warning letters and public statements reaffirming the enforcement push.

The FTC’s Made in USA Labeling Rule codifies the agency’s longstanding “all or virtually all” standard: unqualified U.S.-origin claims are considered deceptive unless final assembly occurs in the United States, all significant processing takes place in the United States, and all or virtually all components are sourced domestically. Earlier this year, on April 14, the FTC announced three enforcement actions and settlements totaling roughly $868,000, and it has put online marketplaces including Amazon and Walmart on notice that the requirements extend to the third-party sellers on their platforms. The executive order also directs the FTC to consider rulemaking that would require marketplaces to verify country-of-origin claims. Retail & Consumer Products Law Observer

Why It Matters: Any brand or retailer using “Made in USA,” “American-made,” or similar language in advertising or on labels should treat this as an active enforcement priority, not a dormant rule. The exposure now reaches beyond manufacturers to retailers, marketplaces, and the third-party sellers on them—meaning platforms and the brands selling through them can share responsibility for origin claims. Marketing and compliance teams should audit U.S.-origin representations across product pages, packaging, and ad creative, confirm substantiation against the “all or virtually all” standard, and document it.

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State “Junk Fee” and Pricing-Transparency Laws Keep Expanding

While federal pricing-transparency rules remain largely sector-specific, states continued to broaden their own “all-in” pricing and surcharging laws through the 2025-2026 legislative cycle. California’s Honest Pricing Law and Minnesota’s all-in pricing statute already require advertised prices to include mandatory fees across industries, and additional states debated or enacted measures addressing surcharging, junk fees, and interchange. Louisiana enacted a law—effective August 1, 2026—prohibiting retailers from imposing a surcharge on consumers who pay with a debit card, and creating a private right of action for consumers harmed by violations.

The result is an uneven patchwork—some bills passed, others stalled as legislative sessions concluded—but the direction is consistent: mandatory fees that are not reflected in the advertised price are increasingly treated as deceptive, and private rights of action in some states add class-action exposure on top of regulator enforcement. All About Advertising Law

Why It Matters: For financial services marketers, fee disclosure is squarely in scope. Advertised prices, rate promotions, and fee schedules that omit mandatory charges can trigger state UDAP and pricing-transparency liability even where federal rules don’t reach. Because these laws vary by state and several carry private rights of action, a company advertising nationally is generally better served designing fee disclosures to the strictest applicable standard than trying to track each state individually.

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On the Radar: The CFPB’s Open Banking Rule Returns to the Drawing Board

The CFPB’s 2026 agenda signals a proposed rule on Section 1033 personal financial data rights—the open banking framework we’ve tracked since it stalled earlier this year—expected in the near term, alongside a payday lending proposal. A reconsidered rule is likely to revisit who qualifies as an authorized third party, whether banks can charge for data access, and data security and consumer-authorization standards.

Why It Matters: Open banking touches nearly every financial institution and fintech. If a revised proposal lands, the public comment window becomes the moment to weigh in on fees, data access, and security obligations. Watch for the proposal and be ready to assess how a reshaped Section 1033 would affect your data-sharing practices.

Connecticut’s “Click to Cancel” Law Takes Effect as States Step Up on Subscriptions

On July 1, an amended “click to cancel” provision in Connecticut’s automatic renewal law took effect, adding to the growing wave of state-level subscription protections that are filling the gap left by the vacated federal Click-to-Cancel rule. Under the updated statute, covered businesses must notify consumers of automatic renewals, provide annual renewal reminders, expand cancellation options, and promptly honor cancellation requests. The core principle is that cancelling a subscription should be as easy as signing up. Attorney General William Tong and the Department of Consumer Protection announced the new rights at a July press conference in Hartford.

Enforcement runs through the Connecticut Unfair Trade Practices Act (CUTPA). Businesses that fail to comply may be investigated by the Attorney General or the Department of Consumer Protection and can face penalties, and consumers can file complaints with either office. AG Tong framed the law bluntly, saying businesses “don’t get to profit by trapping consumers in subscriptions they no longer want,” and that the state “will not hesitate to enforce the law.”

Connecticut is part of a broader trend. With the FTC’s federal Click-to-Cancel rule struck down in 2025 and the agency now enforcing subscription practices under ROSCA and Section 5 while it works on a new rulemaking, states have moved to fill the gap, from New York City’s proposed municipal rule (covered in our April edition) to California’s amended Automatic Renewal Law and the auto-renewal statutes now on the books in more than two dozen states. Connecticut Attorney General

Why It Matters: For any business with subscription or auto-renewal offerings, the compliance obligation is now driven largely at the state level, and the standards vary. Connecticut’s requirements (advance renewal notice, annual reminders, and easy cancellation) echo what other states are adopting, but the specifics such as notice timing, reminder frequency, and cancellation mechanics differ across jurisdictions. Because enforcement runs through state UDAP statutes like CUTPA, non-compliance can be treated as an unfair or deceptive practice with real penalty exposure. Marketing and compliance teams should map their enrollment and cancellation flows against the requirements in every state where they have subscribers, and design to the strictest applicable standard.

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