Newsletter October 13, 2026

Wiley Consumer Protection Download (October 13, 2026)

October 13, 2026

Select Federal Enforcement Actions
Select State Enforcement Actions
Select NAD Advertising Challenge Case Decisions
Federal and State Regulatory Announcements
More Analysis from Wiley

Welcome to Wiley’s update on recent developments and what’s next in consumer protection enforcement and regulation. We cover developments with the Federal Trade Commission (FTC or Commission), the Consumer Financial Protection Bureau (CFPB or the Bureau), and state Attorneys General (AGs), as well as self-regulatory advertising challenges decided by BBB National Programs’ National Advertising Division (NAD). Please reach out to any of our authors with any questions about recent regulatory or enforcement activity on the federal or state level.

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Select Federal Enforcement Actions

FTC Settles with Auto Dealership Group Over Allegedly Deceptive Vehicle Pricing and Prize Promotions. On October 8, the FTC filed a complaint and stipulated order in federal court to settle allegations against an auto dealership group for alleged violations of the FTC Act. The FTC alleged that the group misled consumers by advertising vehicle prices that did not include mandatory fees, packages, and penalties. The defendants agreed to injunctive relief.

FTC Settles with Martial Arts Franchisor and Franchise Sales Organization for Alleged Franchise Rule Violations. On October 5, the FTC filed a complaint and two stipulated orders in federal court to settle allegations against a martial arts franchisor and its franchise sales organization for alleged violations of the FTC Act and Franchise Rule. The FTC alleged that the companies misled consumers by representing that individuals without martial arts experience could successfully operate one or more studios on a semi-absentee basis while working fewer than 15 hours per week. The FTC also alleges the defendants made deceptive earnings claims in franchise disclosure documents. The defendants agreed to pay a total of $1.85 million in addition to injunctive relief.

FTC Warns Health Care Companies Against Deceptive Pricing Practices. On October 5, the FTC announced that Chairman Andrew Ferguson sent warning letters to 24 large health care services companies regarding their obligation to provide patients with timely, accurate, and complete pricing information. The letters state that failing to disclose the price of scheduled health care services may constitute a deceptive practice under Section 5 of the FTC Act, and that a disclosure may still be deceptive if it is incomplete, including if it omits physician or facility fees or covers only part of the anticipated course of care. The letters also explained that compliance with the Centers for Medicare & Medicaid Services’ (CMS) price transparency rules does not create a safe harbor from FTC Act liability. Chairman Ferguson urged the recipients to conduct a comprehensive review of their pricing disclosure practices and take corrective action as needed.

FTC and Two State AGs Sue Contact Lens Retailer Over Allegedly Deceptive Pricing Practices. On October 2, the FTC and the Attorneys General (AGs) of Utah and Nevada filed a complaint in federal court against a contact lens retailer, its owner, and an affiliated entity for alleged violations of the FTC Act, the Restore Online Shoppers’ Confidence Act, the Gramm-Leach-Bliley Act, and state consumer protection laws. The FTC and state AGs allege that the defendants misled consumers by advertising artificially low prices for contact lenses, failing to include substantial mandatory fees for their products. They also allege that defendants failed to adequately disclose cancellation mechanisms related to their AutoRefill subscription. The FTC and state AGs seek monetary and injunctive relief.

Select State Enforcement Actions

Texas Obtains Default Judgment and Permanent Injunction Against Roofing Company and Owner for Allegedly Deceptive Practices. On October 5, a Texas state court entered a final no-answer default judgment and permanent injunction in favor of the state of Texas against a roofing company and its owner, finding that the defendants engaged in deceptive acts and practices in violation of the Texas Deceptive Trade Practices Act. The Texas AG’s complaint alleged that the defendants made false and misleading representations about the roofing services they would provide and often accepted payment for projects in advance while failing to provide the agreed-upon services. The final no-answer default judgement imposes injunctive relief and requires the defendants to pay at least $500,626.64 for consumer restitution and $1.52 million in civil penalties.

California DFPI Settles with Franchise Restaurant Company Over Alleged Franchise Investment Law Violations. On September 29, the California Department of Financial Protection and Innovation (DFPI) announced a settlement with a franchise restaurant company to resolve allegations that the company violated California’s Franchise Investment Law. DFPI alleged that the defendant offered and sold at least 16 restaurant franchises in California without registration, failed to provide prospective franchisees with franchise disclosure documents within the time required by law, and failed to maintain required franchise records. The defendant agreed to pay $120,000 in administrative penalties in addition to injunctive relief.

Washington AG Settles with Emergency Medicine Provider Over Alleged Charity Care Refund Violations. On September 29, the Washington AG announced a settlement with an emergency medicine provider for alleged violations of the state’s Consumer Protection Act. Specifically, the Washington AG conducted an investigation and alleged that the provider engaged in unfair or deceptive acts under the state’s Consumer Protection Act after directly billing patients for medical care and failing to refund certain patients who qualified for charity care refunds, as required by the hospital’s charity care policies. The settlement requires the provider to issue refunds of in the amount of $410,000 to patients and pay $52,500 to the Washington AG.

Select NAD Advertising Challenge Case Decisions

NAD Finds Insufficient Support for Hair and Skin Claims Made by Beauty Brand. On October 5, NAD found that a beauty brand that makes silk pillowcases failed to provide sufficient support for the claims that using its product prevents hair breakage and tangles, skin aging, facial wrinkles, and acne breakouts while sleeping. NAD concluded that the studies provided as evidence to support these claims were not “good fit[s]” to do so. NAD also found that the studies failed to support the specific quantitative outcomes, percentages, and time frames stated by board-certified dermatologists in both written and video endorsements on the product’s website.

Federal and State Regulatory Announcements

Colorado AG Releases Interim Draft AI and Chatbot Rules. On October 6, the Colorado Department of Law released an interim draft of proposed rules implementing Colorado’s Automated Decision-Making Technology (ADMT) Act and Chatbot Safety Act, both of which take effect January 1, 2027. The ADMT Act creates requirements for developers and deployers of ADMT, and gives consumers certain rights, including the right to request and correct personal data used by ADMT. The Chatbot Safety Act imposes new requirements for chatbot operators to estimate the age of users, disclose that users are interacting with AI and not humans, and implement privacy/account management tools for minor users, among other things. The draft rules provide additional guidance on key statutory definitions, deployer and developer responsibilities, consumer disclosures and notices, accessibility and language requirements, and chatbot-specific obligations. Written comments are due by October 26, 2026, and the Colorado Attorney General’s Office will hold a rulemaking hearing on October 26, 2026. Registration information for the hearing can be found here.

CFPB Issues 2025 Fair Lending Report. On October 1, the CFPB issued its annual Fair Lending Report to Congress describing the Bureau’s rulemaking, supervision, enforcement, interagency coordination, and stakeholder engagement activities for calendar year 2025. The report states that the CFPB refocused its fair lending program on proven intentional discrimination involving identifiable victims; stopped using disparate-impact theories in fair lending supervision and enforcement; ceased consulting with institutions regarding special purpose credit programs that use race, color, national origin, or sex as eligibility criteria; and focused on addressing debanking issues. The report also discusses two Regulation B rulemakings that were prioritized in 2025 and finalized in 2026: amendments stating that the Equal Credit Opportunity Act does not authorize disparate-impact liability and revisions to requirements implementing Section 1071 of the Dodd-Frank Act concerning small business lending data.