News & Analysis as of

Medical Debt

Sheppard Mullin Richter & Hampton LLP

Delaware Bans Medical Debt from Consumer Credit Reports

On October 27, 2025, amendments to Delaware’s Medical Debt Protection Act took effect, establishing a total ban on the inclusion of medical debt in consumer credit reports. The amendments, enacted through Senate Substitute 1...more

Brownstein Hyatt Farber Schreck

Brownstein Challenges Colorado Law Prohibiting Medical Debt Reporting

On the heels of the Consumer Financial Protection Bureau’s (CFPB) interpretive rule issued last week explaining that the Fair Credit Reporting Act (“FCRA”) generally preempts state laws related to credit reporting, Brownstein...more

Wiley Rein LLP

Wiley Consumer Protection Download (November 4, 2025)

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CFPB Issues Interpretive Rule Preempting State Medical Debt Reporting Bans. On October 28, the CFPB issued an interpretive rule expressing that the Fair Credit Reporting Act (FCRA) generally preempts state laws that touch on...more

Orrick, Herrington & Sutcliffe LLP

Delaware law barring medical debt from consumer credit reporting takes effect

On October 27, a new Delaware substitute bill, Senate Substitute 1 for SB 156, took effect to prohibit the inclusion of medical debt in consumer credit reports....more

Goodwin

CFPB Issues Rule that FCRA Preempts State Measures Barring Medical Debt

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The Consumer Financial Protection Bureau (CFPB) issued an interpretive rule on October 20, 2025 stating that the Fair Credit Reporting Act (FCRA) preempts state measures barring medical debt in consumer credit reports....more

Sheppard Mullin Richter & Hampton LLP

CFPB Issues Interpretive Rule Asserting Federal Preemption Over State Medical Debt Credit Reporting Laws

On October 28, the CFPB issued an interpretive rule under the Fair Credit Reporting Act (FCRA) declaring that federal law generally preempts state laws governing the content of consumer credit reports. The Bureau’s action,...more

Orrick, Herrington & Sutcliffe LLP

Maryland implements new medical debt laws restricting collection, reporting and judgment practices

On October 14, the Maryland Office of Financial Regulation issued guidance advising collection agencies and consumer reporting agencies to review new requirements and ensure compliance with three new Maryland laws: HB 428...more

Sheppard Mullin Richter & Hampton LLP

Maryland OFR Issues Guidance on New Medical Debt Collection Laws

On October 14, the Maryland Office of Financial Regulation (OFR) issued regulatory guidance explaining three new state laws governing the collection and reporting of medical debt. The guidance clarifies how House Bills 428,...more

Jackson Lewis P.C.

Credit Checks in Hiring: Key Issues for Financial Services Employers After Medical Debt Reporting Restrictions

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Evolving credit checks requirements means employers in financial services are challenged more than ever to stay current because they conduct credit checks on prospective candidates more frequently than those in many other...more

Sheppard Mullin Richter & Hampton LLP

Oregon Enacts New Laws on Medical Debt Credit Reporting, Auto Loan Disclosures and Hidden Online Fees

On September 16, Oregon Governor Tina Kotek announced three consumer protection laws: Senate Bill 605 on medical-debt credit reporting, House Bill 3178 on auto sales and financing disclosures, and Senate Bill 430 on online...more

Orrick, Herrington & Sutcliffe LLP

Oregon enacts new laws to bar medical debt credit reporting, prevent hidden online fees, and strengthen auto loan disclosures

On September 16, Oregon Governor Tina Kotek announced the signings of three new consumer protection laws: (i) SB 605, which prohibits medical service providers from reporting the amount or existence of medical debt to a...more

Frost Brown Todd

Texas Court Vacates CFPB’s Medical Debt Rule: Lender and CRA Takeaways

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On July 11, 2025, the U.S. District Court for the Eastern District of Texas vacated the Consumer Financial Protection Bureau (CFPB)’s medical debt rule. The final rule, originally scheduled to go into effect in March of this...more

Holland & Knight LLP

New Jersey Financial Services Legislative Update

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This alert is part of Holland & Knight's Garden State Initiative, a firmwide effort to enhance coordination among attorneys, clients and professional networks with ties to New Jersey to foster greater collaboration across...more

Orrick, Herrington & Sutcliffe LLP

District court allows plaintiffs to drop the case challenging CFPB’s medical debt rule

On August 1, the U.S. District Court for the Southern District of Texas dismissed without prejudice a case against the CFPB’s medical debt rule (covered by InfoBytes here) following the plaintiffs’ request to withdraw their...more

Brownstein Hyatt Farber Schreck

Federal Court Vacates CFPB’s Medical Debt Rule, Finds FCRA Preempts State Laws

On July 11, 2025, the U.S. District Court for the Eastern District of Texas vacated the Consumer Financial Protection Bureau’s (CFPB) rule prohibiting the inclusion of medical debt on consumer credit reports. The court also...more

Stevens & Lee

New Jersey’s Medical Debt Relief Act Now Fully in Effect

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In July 2024, New Jersey Governor Phil Murphy signed the Louisa Carman Medical Debt Relief Act into law (the Act). The Act protects patients from certain medical debt collection actions and contains several restrictions on...more

Hudson Cook, LLP

Consumer Financial Services Bites of the Month - July 2025 #2 - "July Morning with the CFPB"

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In this month's article, we share some of our top "bites" covered during the July 2025 webinar....more

Fox Rothschild LLP

Court Vacates CFPB Medical Debt Rule: Key Takeaways for Providers

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Earlier this month, the United States District Court for the Eastern District of Texas approved a consent judgment vacating the Consumer Financial Protection Bureau’s (CFPB) Medical Debt Rule. The decision holds that the CFPB...more

Sheppard Mullin Richter & Hampton LLP

Texas Court Vacates CFPB Medical Debt Reporting Rule

On July 11, the U.S. District Court for the Eastern District of Texas vacated the CFPB’s Medical Debt Rule, concluding that the rule exceeded the Bureau’s statutory authority under the Fair Credit Reporting Act (FCRA). The...more

Orrick, Herrington & Sutcliffe LLP

District court tosses CFPB’s medical debt rule

On July 11, the U.S. District Court for the Northern District of Texas vacated the CFPB’s medical debt rule on the grounds that it exceeded the Bureau’s statutory authority and violated both the FCRA and the APA, granting the...more

Troutman Pepper Locke

CFPB Will Not Reissue Medical Debt Advisory Opinion

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On July 14, the Consumer Financial Protection Bureau (CFPB or Bureau) filed a status report announcing its decision not to reissue its Medical Debt Collection Advisory Opinion, which had been issued in 2024 to “remind debt...more

Ballard Spahr LLP

Federal Judge vacates CFPB medical debt rule

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A Texas federal judge has voided a Biden Administration CFPB rule that would have prohibited medical debt in credit reports....more

Holland & Knight LLP

Holland & Knight Health Dose: July 15, 2025

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The U.S. House of Representatives returns from a district work period. The U.S. Senate is expected to consider the $9.4 billion rescissions package that passed the House last month. If not passed by July 18, 2025, the...more

Sheppard Mullin Richter & Hampton LLP

Rhode Island Enacts Ban on Reporting Medical Debt to Credit Bureaus

On June 26, Rhode Island Governor Dan McKee signed companion bills S 0169 and S 0172 into law, twin measures that amend the state’s Deceptive Trade Practices Act and Interest and Usury statute to impose some of the nation’s...more

Sheppard Mullin Richter & Hampton LLP

Oregon Prohibits Medical Debt in Credit Reports

On June 23, Oregon enacted SB 605, barring medical-debt information from appearing in consumer credit reports. The measure, which amends the Oregon Unlawful Trade Practices Act, takes effect January 1, 2026....more

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