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As the government shutdown, which began on October 1, 2025, continues, multiple states, including Oregon, Washington, Arizona and most recently, Pennsylvania, have issued guidance encouraging finance companies, and other creditors, lenders and certain other covered entities to make accommodations to aid consumers impacted by the shutdown.
The Washington Department of Financial Institutions issued a letter to licensed financial institutions and lenders that provides a link to financial resources for federal workers and contractors who are impacted by the shutdown, and encourages those impacted to contact their financial services providers. The letter also encourages chartered and licensed entities to offer assistance to consumers in a manner similar to measures taken during the COVID-19 pandemic. Finally, the letter notes that examiners will generally not criticize working with federal employees and contractors in examinations.
The Oregon Department of Financial Regulation (DFR) issued a Bulletin No. DFR 2025-7 to consumer finance lenders and debt buyers, among others. In the bulletin, the Oregon DFR encourages entities to take steps to offer accommodations to affected debtors such as payment extensions, deferrals and late payment and nonsufficient fund fee waivers.
The Arizona Department of Insurance and Financial Institutions (DIFI) issued Regulatory Bulletin 2025-11 directed towards financial institutions and financial enterprises. Like the Oregon DFR guidance described above, the Arizona DIFI's guidance encourages entities to work with individuals and businesses experiencing difficulties related to the government shutdown and to provide measures such as grace periods for consumers, refraining from charging certain penalty fees and generally communicating with consumers about possible accommodations during the shutdown.
Most recently, on November 4, 2025, the Pennsylvania Department of Banking and Securities (DBS) sent a brief letter to Pennsylvania licensed financial services institutions and lenders encouraging entities to consider ways to provide consumers relief, including general flexibility regarding loans, offering new credit or waiving certain fees. The letter also encourages consumers to contact financial services institutions and lenders if they are dealing with economic hardship.
Finance companies and other lenders are encouraged but not explicitly required to offer any accommodations by these bulletins and letters. Additionally, the guidance provided by these states does not change any statutes, regulations or any requirements related to lending. However, where entities do offer accommodations, such efforts need to still comply with all applicable laws.
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