The U.S. Court of Appeals for the Second Circuit issued a summary order on Jan. 29, 2026, in the consolidated cases of *McNamara v. Fidelis Legal Support Services*, marking the latest development in a multi-state consumer protection enforcement action involving the Consumer Financial Protection Bureau and seven state attorneys general.
The consolidated appeals, numbered 25-1377-cv (lead case), 25-1379-cv, and 25-1418-cv, were heard by a three-judge panel consisting of Circuit Judges Amalya L. Kearse, Raymond J. Lohier Jr., and Steven J. Menashi at the Thurgood Marshall United States Courthouse in New York City.
The case involves an unusual coalition of federal and state enforcement agencies. The Consumer Financial Protection Bureau leads the plaintiffs-appellees, joined by attorneys general from New York, Colorado, Delaware, Illinois, Minnesota, North Carolina, and Wisconsin. New York Attorney General Letitia James, Colorado Attorney General Philip J. Weiser, Delaware Attorney General Kathleen Jennings, Illinois Attorney General Kwame Raoul, Minnesota Attorney General Keith Ellison, North Carolina Attorney General Joshua H. Stein, and Wisconsin's attorney general all participated in the consolidated action.
The defendants-appellants include Fidelis Legal Support Services LLC as the primary defendant, along with The Bush Lake Trust through trustee Timothy Miller as a relief defendant, and Veteris Capital LLC. Additional entities named in the case include Stratfs LLC (formerly Strategic Financial Solutions LLC), Strategic Client Support LLC (formerly Pioneer Client Services LLC), Strategic CS LLC, Strategic FS Buffalo LLC, Strategic NYC LLC, and BCF Capital LLC.
Thomas W. McNamara appears as receiver-appellee in the matter, suggesting the involvement of a court-appointed receiver to manage assets or operations related to the case. The presence of a receiver typically indicates significant regulatory violations that required judicial intervention to protect consumer interests or preserve assets during litigation.
The Second Circuit's summary order format indicates this ruling does not establish binding precedent. According to the court's standard notice, summary orders "do not have precedential effect," though they may be cited under Federal Rule of Appellate Procedure 32.1 and the Second Circuit's Local Rule 32.1.1. Parties citing summary orders must reference either the Federal Appendix or an electronic database with the notation "SUMMARY ORDER" and serve copies on unrepresented parties.
The involvement of both federal and state enforcement agencies suggests the case involves violations of multiple consumer protection laws. The CFPB typically handles matters involving unfair, deceptive, or abusive acts or practices in consumer financial products and services. State attorneys general often join federal actions when violations affect consumers in their jurisdictions or implicate state consumer protection laws.
The business names associated with the defendants suggest involvement in debt collection, financial services, or legal support services. Fidelis Legal Support Services LLC, as the primary defendant, appears to be the main target of the enforcement action. The various "Strategic" entities and their name changes may indicate attempts to restructure or rebrand operations during the course of regulatory scrutiny.
The geographic scope of the case is notable, with state attorneys general from across the country participating. The states involved span from the Northeast (New York, Delaware) to the Midwest (Illinois, Minnesota, Wisconsin) to the West (Colorado) and Southeast (North Carolina), suggesting the alleged violations had nationwide impact.
The appointment of a receiver typically occurs when courts determine that immediate intervention is necessary to prevent further harm to consumers or preserve assets for potential restitution. Receivers often take control of business operations, manage assets, and ensure compliance with court orders while litigation proceeds.
While the Second Circuit's summary order format limits the precedential value of the ruling, the case represents a significant enforcement action given the coalition of agencies involved. Multi-state actions involving the CFPB often result in substantial monetary penalties and operational restrictions on defendants.
The case highlights the ongoing coordination between federal and state consumer protection agencies. The CFPB frequently partners with state attorneys general to leverage their combined enforcement authority and ensure comprehensive consumer protection across multiple jurisdictions.
The timing of the January 2026 summary order suggests the underlying district court proceedings and any subsequent appeals have been ongoing for some time. Consumer protection cases involving multiple defendants and complex business structures often require extensive litigation to resolve fully.
The outcome of this appeal will likely determine the scope of any remedial measures, including potential restitution to affected consumers, operational restrictions on the defendant entities, and ongoing compliance requirements. Given the involvement of a receiver and multiple state agencies, the case appears to involve substantial consumer harm warranting coordinated enforcement action.