Regulatory Roundup: FTC’s Pricing Crackdown, CA Fair Lending, Fake Reviews

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 FTC turns price transparency into a cross-industry enforcement sweep, suing Dollar General and settling with an auto group over “the price you advertise is the price people pay”; California enacts a fair-lending examination law as its AI synthetic-performer ad rules move toward effect; the FTC targets fake reviews and impersonation and signals it may put platforms on the hook; and the CFPB is simultaneously ordered to draw its funding and told to tackle debanking while its permanent director still waits.

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The FTC Goes All-In on Price Transparency

After two editions in which the states did most of the enforcing, the FTC reasserted itself this month, and it did so around a single, simple principle: the price you advertise has to be the price a consumer can actually pay. The agency pursued that idea across four very different industries in a matter of weeks.

On October 26, the FTC and 20 states sued Dollar General, alleging it routinely charged customers more at the register than the shelf or advertised price, citing tens of thousands of pricing complaints the company allegedly failed to address. On October 8, it announced a settlement with auto retailer Greenway Auto Group, which the FTC said advertised vehicle prices thousands of dollars below what buyers actually paid — more than $3,350 above the advertised price, on average, in over 92% of transactions, via tacked-on “administrative,” “dealer,” and “processing” fees. The order requires Greenway to show the actual total price as the most prominent figure in its ads, and it’s the first group action to follow the warning letters the FTC sent to 97 dealer groups earlier in 2026. On October 2, the FTC and the Utah and Nevada attorneys general sued contact-lens retailer Lens.com over prices it advertised in search ads and on its website that consumers allegedly couldn’t actually get. And on October 5, Chairman Andrew Ferguson sent letters to 24 of the country’s largest healthcare companies warning them to give patients accurate pricing. Federal Trade Commission

Why It Matters: Price transparency is now a durable, cross-sector FTC enforcement priority, and the throughline reaches financial services directly. The agency’s theory is consistent whether the product is a car, a box of contacts, or a hospital bill: an advertised price that omits mandatory fees, or that almost no one actually receives, is deceptive. For financial marketers, map that onto rate promotions, “as low as” offers, and fee schedules — if a meaningful share of consumers can’t get the advertised rate or price once mandatory charges are added, you have exposure. And note the mechanics: the FTC is pairing with state AGs, moving from warning letters to actual cases when conduct continues, and asking for the “total price” to be the most prominent number. Audit your advertised prices and rates against what consumers truly pay, and make the all-in figure the prominent one.

California Adds Fair-Lending Exams and AI Ad Rules

California continued building out a consumer-finance and marketing regime that operates independently of whatever the federal agencies are doing. On September 30, Governor Newsom signed AB 801, the California Fair Lending Examination Act. Effective January 1, 2027, it directs the Department of Financial Protection and Innovation (DFPI) to examine state-chartered banks and credit unions that meet HMDA reporting thresholds — at least once every four years — along with licensed mortgage lenders and servicers, for compliance with federal and California fair-lending laws, including ECOA, the Fair Housing Act, the Unruh Civil Rights Act, and California’s Holden Act.

That lands alongside SB 1050, the AI synthetic-performer advertising disclosure law we covered last edition, which was signed September 16 and also takes effect January 1, 2027, requiring clear disclosure when an ad prominently features a realistic AI-generated performer. And in a sign of where state consumer-protection authority is heading, a coalition of eight state attorneys general filed coordinated suits against OpenAI on October 14, applying UDAP-style deception theories to claims about an AI product’s safety. Cooley

Why It Matters: The federal fair-lending posture has softened — the CFPB has stepped back from disparate-impact enforcement — but California just did the opposite, writing recurring fair-lending examinations into law. For lenders operating in California, that means affirmative, scheduled scrutiny of your lending (and the marketing that drives it) against both federal and state standards, regardless of the federal mood. Layer on SB 1050’s AI-disclosure requirement taking effect the same day, and January 1, 2027 becomes a real compliance date for anyone marketing lending products in the state. The broader signal from the OpenAI suits is that state AGs increasingly treat AI claims as ordinary advertising claims subject to deception law. Calibrate your fair-lending and AI-disclosure practices to the strictest applicable standard — which, increasingly, is a state one.

Fake Reviews and Impersonation Draw FTC Fire

The FTC spent October going after deception that’s less about price and more about manufactured trust. On October 22, it sued the operators of a government-impersonation scheme that, according to the complaint, posed as official passport and immigration services — using deceptive ads, misleading promises, and fake positive reviews to appear legitimate and pull consumers in. Fake reviews showed up as a tool in other in-window actions too, as the agency continued leaning on its Reviews and Testimonials Rule.

The agency also moved to widen the net. On September 24, the FTC asked for public comment on whether to expand its Rule on the Impersonation of Government and Businesses to address the role online platforms play in promoting impersonation scams — fraudulent ads and listings that impersonate real companies or agencies. It’s an early rulemaking step, not a final rule, but the direction is pointed: extend responsibility up the chain to the platforms that distribute deceptive content. Federal Trade Commission

Why It Matters: Two things financial marketers should take from this. First, fake or incentivized reviews and false affiliation claims are an active enforcement priority, and the Reviews and Testimonials Rule gives the FTC a direct tool — if your brand, your affiliates, or your lead-generation partners are seeding or buying reviews, or implying endorsements and affiliations that don’t exist, that’s squarely in scope. Second, the proposed platform expansion is the “enabler liability” theme resurfacing — the same principle behind the recent payment-processor cases, now aimed at the platforms that distribute ads, which raises the stakes for anyone marketing through them. The practical move is to monitor what’s being said under your name and by your partners across every channel, and keep documentation that your reviews and endorsements are genuine.

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The CFPB Gets Pulled in Two Directions

The Bureau spent October being pushed and pulled at once. On September 25, a federal court in Oregon — ruling in a case brought by California Attorney General Rob Bonta and a coalition of 22 attorneys general — held that CFPB Acting Director Mark Paoletta must request the funding the Bureau is entitled to draw from the Federal Reserve, finding the prior refusal to draw funds unlawful. In other words, a court is pushing to keep the Bureau funded and functional even as its leadership works to shrink it. Then, on October 14, the CFPB announced a new initiative to address “debanking” — consumer harm the OCC said it uncovered at the nine largest national banks, where access was allegedly denied or restricted based on political or religious beliefs or lawful business activity.

Meanwhile, the leadership question still isn’t settled. Brian Johnson — Trump’s nominee for permanent director — cleared the Senate Banking Committee back in September but has not been confirmed by the full Senate, with a floor vote not expected until after the midterms. And the revised Section 1033 open banking proposal remains under White House review, still unpublished. California Attorney General

Why It Matters: The Bureau is being steered by courts and other agencies as much as by its own leadership right now, which makes its near-term posture genuinely hard to predict. The debanking initiative is worth watching closely — it’s a rare instance of this CFPB leaning into a new consumer-facing issue, and it could touch account-marketing, eligibility, and communications practices at large banks. For planning purposes, assume continued federal volatility and keep your attention on the state and multistate activity that has been driving most of the real enforcement. And watch for that open banking proposal — when it publishes, the comment window will matter to nearly every bank and fintech.

On the Radar: New York City’s Click-to-Cancel Rule Takes Effect, and States Keep Enforcing Auto-Renewal

New York City’s first-in-the-nation municipal click-to-cancel rule took effect October 1, and the city’s consumer agency is now accepting complaints. It requires that any auto-renewal or continuous-service subscription offered to NYC consumers be cancellable through the same method used to sign up, with penalties starting at $525 per violation and escalating for repeat violations. The states kept enforcing in parallel: on October 14, Vermont’s attorney general settled with UniFirst for $60,000 over alleged violations of the state’s automatic-renewal law — a small number, but a clear signal that these requirements are being actively enforced.

Why It Matters: Subscription and auto-renewal compliance keeps fragmenting to the state — and now city — level, and the standards vary. If you run any recurring-billing offer with NYC subscribers, October 1 was a hard deadline: your cancellation path has to be as easy as your sign-up path. And the Vermont settlement is a reminder that even modest-dollar cases get brought. Map your enrollment and cancellation flows against every jurisdiction where you have subscribers, design to the strictest standard, and treat “as easy to cancel as to sign up” as the baseline everywhere.

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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.