Goodwin Releases 2025 Consumer Financial Services Year in Review on March 31, 2026[1][2][5]

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Score
9

Why it matters

Goodwin Law published its annual "Consumer Financial Services: 2025 Year in Review" report on March 31, 2026, summarizing key trends in cards, payments, consumer banking, and fintech, with a forward look to 2026. The core developments in 2025 included a sharp decline in federal enforcement—Goodwin tracked 12 actions in cards/payments/banking (down from 15 in 2024), yielding $372 million in penalties from CFPB, FTC, FDIC, DOJ, and state AGs—alongside CFPB retreats like dismissing cases, pausing supervision, and vacating its 2024 $8 credit card late fee rule via a Texas court ruling in April 2025[2][5][7]. States like Texas and California stepped up with AI oversight laws for fintechs, while banks partnered with tech firms for embedded finance amid OCC's November 2025 RFI on community bank tech providers[1][2][5].

Key players include federal agencies (CFPB retreating under Trump’s second term started January 2025, with FTC/OCC/FDIC/states filling gaps), DOJ, state AGs/regulators, and firms like a bankrupt BaaS platform sued by CFPB in August 2025 for CFPA record-keeping failures, plus MoneyLion's November 2025 CFPB settlement ($1.75M restitution for MLA violations)[2][5][7]. Legislation and policy involved the vacated late fee rule (exceeding authority under CARD Act/APA), state AI laws, and emerging 2026 debates on CFPB's open banking rule (expected interim final in 2026), fraud models, fees, plus Trump's supported Credit Card Competition Act (reintroduced 2026, mandating dual networks to cut swipe fees) and 10% APR cap proposals[1][2][5][6].

This shift from federal to fractured state/federal oversight built on 2024's enforcement peak (83 actions vs. 51 in 2025), driven by Trump's rollback of CFPB/FTC, creating a patchwork of state regimes on fees/disclosures/digital assets[3][7]. It's newsworthy now amid March 31 report release, aligning with 2026 forecasts like $13.5T US card transaction value, A2A payment growth, CFPB open banking push, and legislative markups on CCCA, as institutions brace for litigation, AI scrutiny, and open finance data-sharing rules[1][2][4][6].

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