Following a brief decline in August, consumer litigation has regained momentum in September. WebRecon’s latest data shows that filings under the Telephone Consumer Protection Act (TCPA) and the Fair Debt Collection Practices Act (FDCPA) rose significantly in September. Although Fair Credit Reporting Act (FCRA) cases dipped slightly, year-over-year comparisons confirm sustained litigation growth across all three statutes relative to September 2024. Complaints to the Consumer Financial Protection Bureau (CFPB) also increased, continuing the broader upward trajectory that has defined 2025.
Year-to-date (YTD) totals remain well above 2024 levels, demonstrating a continuation of the broader trend of rising litigation this year. Particularly notable is the prevalence of TCPA class actions, with nearly three-quarters of filings brought on a class-wide basis. The dominance of class litigation amplifies companies' financial and reputational exposure, underscoring why even modest monthly increases in filings can translate into significant risk.
Key Statistics
- Telephone Consumer Protection Act (TCPA): 287 cases filed in September, up 23.7% from August, and up 108% compared to last year. YTD filings remain more than 50% higher than in 2024. 78% of TCPA cases were filed as class actions.
- Fair Debt Collection Practices Act (FDCPA): 428 cases filed, representing a 22.6% increase from August. YTD totals are nearly flat compared to last year, but FDCPA filings continue to trend upward from the August dip.
- Fair Credit Reporting Act (FCRA): 737 cases filed, a 4.7% decline from August. Despite the monthly decrease, FCRA cases remain up 58.6% compared to August of last year and 30.7% YTD compared to 2024.
- Consumer Financial Protection Bureau (CFPB) Complaints: 28,125 complaints submitted, up 0.9% from August. YTD totals are now nearly double last year’s numbers, continuing a remarkable growth trajectory.
Most Active Courts
- California Central District Court - Western Division - Los Angeles (99 lawsuits filed)
- Georgia Northern District Court – Atlanta (76)
- Illinois Northern District Court – Chicago (58)
- California Central District Court - Eastern Division – Riverside (48)
- Florida Middle District Court – Tampa (40)
- Florida Southern District Court – Miami (40)
- Florida Southern District Court - Fort Lauderdale (31)
- Texas Northern District Court – Dallas (29)
- New York Eastern District Court – Brooklyn (28)
- Pennsylvania Eastern District Court – Philadelphia (28)
Top States for CFPB Complaints
- Texas (6,227 complaints)
- California (2,782)
- Florida (2,710)
- Georgia (2,204)
- North Carolina (1,260)
- New York (1,053)
- Illinois (1,019)
- Pennsylvania (935)
- Virginia (832)
- Arizona (684)
The September rebound in TCPA and FDCPA filings demonstrates that August’s declines were temporary rather than indicative of a broader shift. TCPA class actions remain elevated at historically high levels, and CFPB complaints continue to increase at a remarkable pace. Even with a modest downturn in FCRA activity, the YTD data across all three statutes reflects a litigation and regulatory environment that remains consistently active. For consumer finance companies, these developments highlight the importance of sustained compliance efforts, careful monitoring of enforcement trends, and proactive litigation strategies in navigating an increasingly challenging risk landscape.
