October 2025 Litigation Update: A Volatile Month Underscoring Persistent Litigation Exposure

Consumer litigation activity remained mixed in October, reflecting continued volatility across key consumer protection statutes. WebRecon’s latest data shows that filings under the Fair Debt Collection Practices Act (FDCPA) and Fair Credit Reporting Act (FCRA) rose significantly during the month, while Telephone Consumer Protection Act (TCPA) cases and Consumer Financial Protection Bureau (CFPB) complaints experienced some decline. Despite these fluctuations, year-to-date (YTD) figures continue to demonstrate broad growth compared to 2024, suggesting that consumer litigation risk remains persistently elevated heading into the final months of the year.

TCPA case volume dropped 18.4 percent from September, though class actions continue to dominate this area, representing 72.8 percent of all TCPA filings. In contrast, FDCPA filings increased 14.9 percent, and FCRA cases surged 24.7 percent for the month. CFPB complaints fell 8.6 percent from September but remain up 93 percent YTD, while TCPA litigation overall is still 56.6 percent higher than this point last year. The ongoing imbalance among these categories illustrates that even when one area cools temporarily, others continue to accelerate, keeping overall enforcement and litigation exposure high.


Key Statistics

  • Telephone Consumer Protection Act (TCPA): 235 cases filed in October (down 18.4 % from September); 171 of these (72.8 %) were class actions. TCPA filings remain up 56.6 % YTD compared to 2024.
  • Fair Debt Collection Practices Act (FDCPA): 493 cases filed (up 14.9 % from September); 17 of these (3.4 %) were class actions. FDCPA cases are up 2.9 % YTD.
  • Fair Credit Reporting Act (FCRA): 919 cases filed (up 24.7 % from September); 12 (1.3 %) were class actions. FCRA cases are up 36.4 % YTD.
  • Consumer Financial Protection Bureau (CFPB) Complaints: 26,476 complaints submitted (down 8.6 % from September) but up 93 % YTD compared to 2024. 


Most Active Courts

  • Georgia Northern District – Atlanta (77 lawsuits)
  • California Central District – Western Division – Los Angeles (70)
  • Illinois Northern District – Chicago (63)
  • Florida Middle District – Tampa (46)
  • California Central District – Southern Division – Santa Ana (37)
  • Florida Southern District – Fort Lauderdale (33)
  • California Southern District – San Diego (31)
  • California Central District – Eastern Division – Riverside (30)
  • California Eastern District – Sacramento (28)
  • Florida Southern District – Miami (27) 


Top States for CFPB Complaints

  • Texas (4,334 complaints)
  • California (2,816)
  • Florida (2,793)
  • Georgia (2,218)
  • North Carolina (1,092)
  • Illinois (1,021)
  • Virginia (981)
  • New York (909)
  • Pennsylvania (906)
  • Arizona (828)

October’s data underscores that consumer litigation remains uneven yet persistently active. TCPA filings declined notably, but their high class-action concentration continues to drive disproportionate exposure. Meanwhile, rising FDCPA and FCRA filings signal that plaintiffs’ counsel remain focused on traditional consumer protection statutes, even as complaint volume through the CFPB moderates. For consumer-finance companies, the combination of strong YTD growth, heightened class-action activity, and expanding enforcement oversight reinforces the need for continued vigilance, strengthened compliance controls, and proactive litigation management as the year draws to a close.

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