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Make sure to visit Troutman Pepper Locke’s Regulatory Oversight blog to receive the most up-to-date information on regulatory actions and subscribe to our mailing list to receive a monthly digest.
Regulatory Oversight will provide in-depth analysis into regulatory actions by various state and federal authorities, including state attorneys general (AG) and other state administrative agencies, the Consumer Financial Protection Bureau (CFPB), and the Federal Trade Commission (FTC). Contributors to the blog will include attorneys with multiple specialties, including regulatory enforcement, litigation, and compliance.
By Troutman Pepper Locke State Attorneys General Team
Thirty states and the District of Columbia held elections for AG in 2026. Click below to see the current results for all 31 races, including the states where new AGs have been elected. Please check back throughout the day for the latest updates on our Regulatory Oversight Blog as additional races are called and results are verified.
By Troutman Pepper Locke State Attorneys General Team
Troutman Pepper Locke is proud to sponsor the Government Investigations & Civil Litigation Institute’s (GICLI’s) 12th Annual Meeting in Fort Lauderdale, FL. Ryan Strasser will moderate the “Litigating on Their Turf: Strategic Responses to State AG Enforcement” session, and Ghillaine Reid will be a panelist on the “Coordinating the Defense: Corporate and Outside Counsel in Government Investigations” session.
By Chris Willis, Stefanie Jackman, and Michael Yaghi
In this special crossover episode of Regulatory Oversight and The Consumer Finance Podcast, Chris Willis, Stefanie Jackman, and Mike Yaghi discuss California Governor Gavin Newsom’s appointment of former CFPB Director Rohit Chopra to lead the state’s newly created Business and Consumer Services Agency (BCSA).
By Justin Weber and Carlin McCrory
In this episode of Payments Pros, host Carlin McCrory is joined by Justin Weber, a business litigation partner at Troutman Pepper Locke, to discuss arbitration and the growing challenge of mass arbitration for payments and fintech companies.
In this episode of Payments Pros, host Carlin McCrory speaks with Frank Van Driessche, head of the ISO 20022 practice at Federal Reserve Financial Services, about the global messaging standard reshaping the payments industry.
By Abigail Hazlett and Camille Grout
On September 18, 2026, the Department of Justice (DOJ) issued two significant updates to the Justice Manual affecting False Claims Act (FCA) enforcement. First, DOJ attorneys are now required to affirmatively assess whether dismissal of a qui tam action serves the government’s interests whenever the DOJ declines to intervene. Second, DOJ clarified that it cannot bring criminal or civil cases based solely on violations of agency guidance documents, while preserving several ways guidance may still be used as evidence. Together, these revisions signal a shift toward curbing “meritless” qui tam suits and reinforcing that FCA liability must be grounded in actual legal requirements, not sub-regulatory guidance alone.
By Chris Carlson, Lauren Fincher, Erin Harrigan, and Sydney Goldberg
Pharmacy benefit managers (PBMs) that serve large self-insured health plans will have to give employers a detailed account of how they are paid under a rule the U.S. Department of Labor (DOL) finalized on October 29, 2026. Employers will also have the right to audit that information.
By Troutman Pepper Locke State Attorneys General Team
The state of Texas secured a $45 million settlement from Gilead Sciences Inc. over allegations that its patient-support programs improperly encouraged prescriptions for drugs covered by Medicaid. This case highlights both how patient-support services can draw scrutiny when they provide something of value to prescribers, even when no money changes hands, as well as the ongoing role of state AGs in health care enforcement.
By Troutman Pepper Locke State Attorneys General Team
A final court order does not necessarily mean an end to the involvement of state AGs in an enforcement action. As a recent filing shows, state AGs are now treating failure to comply with post-judgment permanent injunctions as standalone contempt actions.
By Troutman Pepper Locke State Attorneys General Team
On September 17, 2026, 20 state AGs led by Alabama AG Steve Marshall issued a letter to the federal government concerning Chinese-sourced ingredients in compounded GLP-1 drugs and peptides. Addressing their letter to Secretary of State and National Security Adviser Marco Rubio, the AGs characterize these supply chain issues as a national security concern, criticize a 2025 Food and Drug Administration (FDA) policy for exacerbating the problem, and seek federal intelligence on foreign GLP-1 and peptide supply chains and improved information sharing between federal and state partners.
By Troutman Pepper Locke State Attorneys General Team
Health care market pressures and the evolving role of state enforcement were the focus of a recent National Association of Attorneys General (NAAG) Eastern Region meeting. Tracy Wertz, chief deputy AG of the Antitrust Section in the Pennsylvania AG’s Office, moderated the discussion with Leslie V. Gordon, director at the U.S. Government Accountability Office. Together, they addressed hospital closures, physician consolidation, rural health funding, and health care fraud, with particular attention to how state AGs can monitor transactions and respond to changing market conditions.
By Troutman Pepper Locke State Attorneys General Team
On October 23, 2026, a coalition of 10 state AGs filed a motion requesting that the U.S. District Court for the District of Oregon reject an attempt by the Office of the Comptroller of the Currency (OCC) to stay the states’ challenge to the OCC’s new interest-on-escrow preemption rules in State of Oregon et al. v. OCC et al.
By Troutman Pepper Locke State Attorneys General Team
Pennsylvania and New York secured significant conditions on Colas Inc.’s acquisition of Suit-Kote Corp., two asphalt and road-maintenance companies, after the Justice Department ended its review. The states’ continued scrutiny illustrates how state AGs can pursue merger remedies when federal regulators step aside, but state or local competition concerns remain.
By Jay Dubow and Ghillaine Reid
On October 23, the Securities and Exchange Commission (SEC) Division of Examinations (the Division) released its fiscal year 2027 Examination Priorities, with significant attention to emerging technology, cybersecurity, retail investor protection, and anti-money laundering (AML) compliance. The priorities were developed in coordination with divisions and offices across the SEC and reflect examination observations, market developments, investor concerns, industry engagement, and emerging trends. They identify areas the Division believes currently present heightened risks to investors or market integrity and will help guide its risk-based examination program. Importantly, the Division makes clear that the priorities are not exhaustive, and the Division may adjust its focus throughout the year in response to emerging risks, products and services, market events, and investor concerns. Nevertheless, the priorities provide important guidance for financial services firms as they assess their compliance and risk-management programs for the year ahead.
By David Navetta, Stephen C. Piepgrass, Edgar Vargas, and Daniel Waltz
Good decisions depend on good data. Football coaches study film to learn what an opponent calls on third-and-long so they can deploy the right defense. Businesses collect vast amounts of data to develop and market new products. No general counsel (GC) would approve a major business decision without first gathering the available facts and conducting the necessary legal research. Yet GCs make high-stakes regulatory decisions every day without a complete, data-driven picture of the enforcement landscape. Sometimes the gamble pays off, but when it does not, it can cause serious problems for the company.
By Troutman Pepper Locke State Attorneys General Team
On October 19, 2026, California AG Rob Bonta announced a $6 million settlement with Chrome Holding Co., the successor to the genetic testing company 23andMe. The settlement resolves a lawsuit that California filed against the company in May 2026 arising from a 2023 data breach as well as California’s objections to 23andMe’s sale of consumers’ genetic data as part of the company’s bankruptcy proceedings. California’s settlement comes on the heels of a recent settlement with the 42 other state AGs who filed proofs of claim in the bankruptcy proceedings. (See our coverage of the July 2026 multistate settlement here.)
By Edgar Vargas, Matthew Berns, and Sadia Mirza
California’s latest legislative session delivered a wave of privacy developments, with Governor Gavin Newsom signing a broad set of measures affecting consumer rights. But one proposal did not make it across the finish line: AB 1542, which would have prohibited the sale or sharing of sensitive personal information with third parties. This article examines the governor’s veto of AB 1542 and what it means for the direction of privacy policy and for businesses and consumers subject to California law.
By Troutman Pepper Locke State Attorneys General Team, Laura Hamady, and Shelby Dolen
State AGs are signaling that artificial intelligence (AI) chatbot user data will face scrutiny, even in bankruptcy. On October 14, 2026, a bipartisan coalition of AGs from 39 states and the District of Columbia filed a notice in the Chapter 11 case of Character Technologies, Inc. (Character.AI), outlining the child-safety and privacy protections they will press for in any sale. The notice comes just days before California announced a $6 million settlement with the successor to 23andMe, resolving claims over 23andMe’s 2023 data breach and ending California’s appeal of the 2025 bankruptcy sale of customers’ genetic data, the closest precedent for a Character.AI sale. AI companies, acquirers, and investors should take note.
By Ashley L. Taylor, Jr., Clayton Friedman, Chris Carlson, Chanel Thomas, Alexandra Lancey, Matthew Berns, and William LaRosa
Eight state AGs filed separate but coordinated lawsuits against OpenAI on October 14, alleging that the company misled consumers about ChatGPT’s safety and failed to adequately protect children and other users from harmful interactions.
By Stephen C. Piepgrass and Reade Jacob
On October 20, 2026, New Jersey AG Jennifer Davenport and the Division of Gaming Enforcement (DGE) announced that a set of data-driven responsible gaming requirements has been codified into state regulations with the force of law. New Jersey is now the first state to require these measures by regulation. The final regulations are available here.
By Stephen C. Piepgrass and Reade Jacob
A bipartisan coalition of 39 state AGs, joined by the District of Columbia, has asked the U.S. Supreme Court to review a closely watched dispute over whether federally regulated prediction markets may offer sports-event contracts without complying with state gambling laws.
By Troutman Pepper Locke State Attorneys General Team
On October 14, 2026, Vermont AG Charity Clark announced a settlement with UniFirst based on allegations that the company did not comply with Vermont’s auto-renewal law.
By David Fialkow and Michael Lafleur
The national conversation about so-called junk fees — charges hidden until the final stage of a consumer transaction — has accelerated dramatically over the past three years. Federal regulatory efforts have stalled or been struck down. Most notably, on July 8, 2025, just days before a scheduled compliance deadline, the Eighth Circuit vacated the FTC’s sweeping amendment to its Negative Option Rule on procedural grounds.
By Troutman Pepper Locke State Attorneys General Team
On October 2, 2026, the FTC, and the AGs of Utah and Nevada, sued online contact lens retailer Lens.com, alleging that the company advertised contact lenses at prices significantly lower than what consumers ultimately paid after mandatory “Taxes & fees” charges were added during checkout. The complaint, filed in the U.S. District Court for the District of Nevada, reflects recurring themes in consumer protection enforcement, including price transparency, online sales practices, automatic renewal programs, and coordinated federal-state enforcement.
By Troutman Pepper Locke State Attorneys General Team
Pennsylvania AG Dave Sunday announced a settlement on September 28, 2026, with Mavis Tire Supply to resolve allegations that the company engaged in deceptive sales and repair practices. Under the settlement, filed in the form of an Assurance of Voluntary Compliance (AVC), Mavis agrees to pay $215,000 — $190,000 for consumer restitution and $25,000 for investigative costs. The agreement also provides for a suspended $100,000 civil penalty that could become due if Mavis is found to have violated the agreement. Mavis agreed to the settlement without admitting liability or any wrongdoing.
Stephanie Kozol, Senior Government Relations Manager – State Attorneys General, also contributed to this newsletter.
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Performance on Trial: The Construction Manager’s Standard of Care Examined from All Angles
December 2, 2026 | 4:15 PM – 5:30 PM ET
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ACI’s 31st Annual Conference on Drug & Medical Device Litigation – 2026
December 2 – 3, 2026
New York Marriott Marquis
1535 Broadway, New York, NY 10036
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Fundamentals of Investment Adviser Regulation 2026
November 19, 2026 | 2:30 PM – 3:30 PM ET
PLI New York
1177 Avenue of the Americas, Entrance on 45th Street, New York, NY 10036
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2026 Advanced eDiscovery Institute
November 19 – 20, 2026
Capital Hilton
1001 16th Street NW, Washington, DC 20036
