insideARM Yearly Recap – 2025

Published on January 5, 2026 at 10:00 am

Missy Meggison

General Counsel & Editor at insideARM
letters spelling the word recapann-h / pexels

News in the ARM industry never stops and sorting out what’s news and what’s noise can be a challenge. To help you wade through it all, on Mondays we typically publish a recap of the news we found most interesting during the previous week and, more importantly, why we chose to publish it. Since today marks the first work week of 2026, we’re going to change things up and focus on the top news of 2025 and why we think these stories are worth revisiting as we shake off the holiday fog and march into 2026.  

The top news categories of 2025 were:  

  • The CFPB’s Weakening and Reduction in Influence  
  • States Strengthening their Consumer Protection Measures  
  • Operational Challenges, Technology Advancements, and the Modern consumer  
  • Noteworthy Consumer Protection Litigation (FDCPA, TCPA, State Laws)  

The CFPB’s Weakening and Reduction in Influence (top 5)  

The year started with Rohit Chopra’s removal and a lawsuit filed to challenge the “Shutdown” of the CFPB (The suit remains pending; you can find an updated status here).    

2025 was a wild ride, and here are the top 5 news stories we see as most relevant to 2026 that transpired after former director Chopra’s removal and the lawsuit challenging the shutdown:  

  • In April 2025, the CFPB circulated an internal memo regarding its enforcement priorities, in which its Chief Legal office explicitly stated it was shifting from all previously listed priorities and moving in a different direction. 
  • In July 2025, the CFPB opted not to reissue its Medical Debt Collection Advisory Opinion. This decision comes as part of the CFPB’s broader initiative to withdraw numerous policy statements, interpretive rules, advisory opinions, and other guidance documents. This was a very big deal. The Chopra-era CFPB was laser focused on the elimination of the ability to collect medical debt. This walk-back was a clear indication in a string of walk-backs that indicated the Chopra- era CFPB was no more. 
  • In September 2025 the CFPB issued a proposal to limit its supervision of nonbanks by adopting a more stringent definition of “risks to consumers.”  This change would mean nonbank financial institutions might anticipate a reduction in supervisory actions by the CFPB. 

States Strengthening Their Consumer Protection Measures  

Before he was removed, former director Chopra’s CFPB issued a report titled “Strengthening State-Level Consumer Protections,” along with an accompanying Compendium of Guidance Documents. The report included key recommendations for states to consider and was widely thought to encourage states to get more active in the consumer protection space under the new federal administration.   

Here are the top 5 pieces of news we found most relevant against that backdrop:  

  • April 2025- California attempts to fill the void created by the weakening of the CFPB. In response to the reduction in federal oversight, California introduced legislation to enhance its consumer protection laws. As the CFPB weakened throughout the year, industry experts cautioned that states would step up ultimately creating a patchwork of inconsistent regulations. California wasted no time on being first to the plate.  
  • June 2025- Illinois Amended its Collection Agency act to provide a way for consumers to avoid liability for a coerced debt. The concept of “coerced debt” is relatively new and seems to be shaping up to be an area that we’re going to see state by state requirements dictating what qualifies as “coerced debt” and when collections must be stopped in light of such allegations. We may see more of this in 2026. 
  • June 2025- New York published a report that highlighted areas to strengthen consumer financial laws. The report identified five areas where state and city intervention may be necessary and called for regulation of certain loan products. New York regulations are often copied by other states. Though not much has happened with this yet, it remains something to keep an eye on in 2026. 
  • December 2025- ACA filed a lawsuit in Colorado regarding its prohibition of medical debt from credit reports. A number of states have passed similar laws in recent years, and those collecting in the medical debt space should keep an eye on this legislation and its outcome.  
  • December 2025-  Rohit Chopra takes new role, leading a consumer protection group for blue-state AGs. Throughout 2025, industry stakeholders have been closely monitoring state-level legal and regulatory developments. This move continues to tell that story; and with Mr. Chopra’s record, this new endeavor might be pivotal heading into 2026.  

Bonus- Not all bad news from the states: In June 2025, Florida enacted new legislation that makes it clear emails are allowed between 9pm and 8am. Debt collectors have struggled to make modern technology fit within the confines of the (enacted in 1977!) Fair Debt Collection Practices Act, and consumer attorneys have certainly exploited these gaps. It’s refreshing to see a state utilize some common sense and let modern technology be used in ways that make sense. Hopefully some other states will follow suit instead of freezing debt collectors in the 1970s. 

Operational Challenges and Technology Advancements  

We covered quite a few new stories that fit this category. Here are our top 5 from the year that we think warrant a re-read as we head into 2026:  

  • The compliance perspective on AI. From clarifying what “artificial intelligence” really means, to outlining the new demands on compliance officers created by incorporating AI, to use cases, this article can be useful to those just starting in AI and those who have already begun to utilize this technology. For those just getting started, this article outlines an easy-to-follow path to help get you started. For those who have already implemented AI, Sara Woggerman’s insights can be a useful tool to ensure compliance hasn’t been left out of the equation. 
  • The pillars of a customer-centric debt collection strategy. In today’s environment, successful organizations meet consumers where they are at. This approach requires organizations to evaluate their processes and pivot as necessary. This take on key areas of focus can be a helpful place to start or a good checkpoint for those who have already shifted to a consumer-centric strategy.   
  • The best practices for balancing compliance and consumer experience in digital debt collection. It can be a challenge to use 2025 technology to meet 2025 consumer expectations while adhering to the passed-in-1977 FDCPA, a not-so-all-encompassing Reg F, and a myriad of state laws. This article provides key insights into how to stay on top of the shift to a consumer-centric compliance model as well as best practices for doing so. 
  • The importance of focusing on people processes, and Technology. Too often, one or more of these pillars are overlooked or not stressed as much as the others. This article is a good reminder of why all three are crucial.  
  • Taking  the artificial intelligence conversation from hype to practical results. This article explores AI in financial services, its applications across the consumer lending lifecycle, and what to know about adopting it in operations. In the ARM industry, we know AI is on the horizon; the challenge is what to do about it.  Part of answering that question is looking at how lenders are harnessing and utilizing AI, which is provided in several concise examples in this article.     

Noteworthy Consumer Protection Litigation (FDCPA, TCPA, State Laws)  

Last but certainly not least, in 2025 there were several legal decisions that may affect the ARM industry. Here are our top 5:  

  • June 2025- No Shotgun pleadings. In this case, the court took specific issue with “shotgun” style pleadings and cautioned that Reg F does not equal the FDCPA. The opinion is full of language in the debt collector’s favor that others can use to fight vague FDCPA actions, or cases based entirely on alleged violations of Reg F. It’s a must read for those involved in the defense of FDCPA claims. 
  • July 2025- A win in a wrong number case that alleged violations of the Fair Debt Collection Practices Act (FDCPA) and Texas Debt Collection Act (TDCA). This one may have flown under the radar, since it was a district court decision. We’re including it here because as long as we continue to use phones, wrong number cases will continue to exist. This is a good common-sense decision to keep on hand should your organization be the recipient of one of these types of cases. 
  • October 2025- Court upholds sanctions against consumer attorney. In this case the consumer’s counsel acted so egregiously that an appellate court upheld sanctions against them. As the court put it, the consumer’s attorneys engaged in “a campaign of deception”. It’s an understatement to say that manufactured FDCPA claims are an extremely frustrating part of the debt collection business. Although the circumstances of other manufactured suits may not be as clear-cut as those here, this is a good case to read and be aware of- especially if your organization has dealt with suits from this firm based on handwritten letters with buried disputes. 
  • November 2025- Debt collector wins on Bona Fide Error Defense. Many bona fide error defenses fail. We’re including this one because it was successful and involves a great breakdown of the nuance of the BFE defense from the Ninth Circuit Court of Appeals. This breakdown can be a useful measuring stick to ensure your organization’s procedures can provide a defense should one ever be needed. 
  • December 2025- Right to Cure Requirements. This podcast addresses state law ‘right to cure’ requirements, recent case law, and risks to debt collectors. The conversation also clears confusion by highlighting the 14 jurisdictions that require a right to cure notice. This 8.5-minute podcast is a must listen to for anyone collecting in right to cure states (and those that want to be sure they aren’t!).     

insideARM perspective- Looking at the year ahead  

The trends of 2025 will continue. The CFPB, now a shell of what it once was, will continue to limp along. The biggest potential for regulatory upset comes from the former director Chopra’s new role with the blue state AGs. On the tech front, ARM industry stakeholders continue to try to find ways to bring AI from something talked about, to something leveraged. Will 2026 be the year we see significant movement there? Maybe. Whatever happens in 2026, we’ll be monitoring it, and we’ll continue to bring you the news that we see as most relevant to the industry.