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Industry Lawsuits Target State Medical-Debt Bans After CFPB Preemption Shift

Judges will now decide whether federal credit law overrides state restrictions across roughly 15 states.

Overview

  • The CFPB issued an Oct. 28 interpretive rule asserting the Fair Credit Reporting Act generally preempts state laws that bar or limit medical-debt reporting, though the guidance is not legally binding.
  • Brownstein, on behalf of ACA International, filed a federal suit challenging Colorado’s HB 23-1126, arguing FCRA preemption and claiming the law unlawfully restricts accurate commercial speech under the First Amendment.
  • The litigation follows a blocked Biden-era CFPB rule from January that would have curbed medical-debt reporting nationally, which the Trump administration declined to defend in court.
  • Between 14 and 15 states have enacted protections restricting medical-debt entries on credit reports, including California, Colorado, Maine, New York, Virginia and Washington, leaving those laws’ futures uncertain.
  • Consumer advocates warn that restoring medical-debt reporting could damage credit access for millions, with KFF estimating $220 billion in unpaid medical bills in 2024 and about 14 million adults owing more than $1,000.