Navigating Complexity in US Consumer Financial Services: A Look Back at 2025

Mayer Brown’s broad Financial Services practice has a long history of providing meaningful insights on how rapidly evolving environments for financial products may affect their business activities through both thought leadership publications and client engagements. Our attorneys covering spaces including financial services regulatory advisory, financing and corporate transactions, and litigation and enforcement representation understand that the value we provide consists not only of working within the environment that exists in the moment, but also in active tracking of how environments have changed over time and prediction of how they will continue to shift in the near and longer terms.

The past year presented financial services market participants with numerous legal and regulatory curveballs demanding reasoned response. The federal environment generally faced deregulatory pressures, but the path to a more open market has not been particularly smooth. Simultaneously, many state actors have sought to fill various perceived gaps in regulation that federal pullback has exposed. The year that comes is shaping up to be no less challenging. As you navigate 2026, Mayer Brown seeks to be a partner in charting a path that both identifies new opportunities and reasonably mitigates new risks.

In this publication, we offer you a look back at select major developments in the US regulatory requirements applicable to consumer and small business financial products and services. This year’s compilation of articles (presented as they were originally published as examples of the kinds of financial services Legal Updates you should expect from Mayer Brown over time) addresses key federal and state regulatory issues that may affect business opportunities and risks across US jurisdictions and/or financial asset classes. Specifically, we have chosen to highlight articles covering CFPB and state law developments, as well as developments affecting bank partnership lending models, automobile financing, buy-now/pay-later (BNPL) financing, earned wage access (EWA) programs, home improvement and solar financing, and small business loans and credit alternatives (such as merchant cash advance programs).

It is our hope that, by revisiting the articles applicable to the types of programs and transactions in which you regularly engage, you will gain a better sense of how US markets are changing over time.

Upon review, please feel free to reach out to Mayer Brown—including through the authors of any article of interest for your business or your key client relationship managers—for further analysis of 2025’s key developments and/or a sense of what you should expect in the coming year.