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CFPB Launches Additional Rulemaking, Procedural and Administrative Changes

The CFPB has continued to announce additional procedural, rulemaking and administrative changes, with the latest being three postings to the Federal Register on June 18, 2025: 1) a final rule rescinding the Procedure Relating...more

Federal Judge's Decision May Bind CFPB to Previously Withdrawn Guidance Documents

U.S. District Court Judge Barbara J. Rothstein granted, in part, the CFPB's motion to withdraw its amicus brief filed by the Biden-era CFPB regarding the "proper interpretation of the Fair Debt Collection Practices Act's...more

Texas Governor Signs Commercial Sales-Based Financing Legislation Into Law

Texas Gov. Greg Abbott signed House Bill (HB) 700 into law on June 20, 2025, despite significant opposition from industry with respect to one critical legislative provision. This follows the legislation's approval by the...more

CFPB Budget Cuts Blocked by Senate Parliamentarian

Senate Parliamentarian Elizabeth MacDonough ruled that the Trump Administration and congressional Republicans cannot use the pending budget reconciliation bill to eliminate funding to the CFPB in a June 23, 2025,...more

Federal Reserve Office of the Inspector General to Expand Its Investigation of CFPB

The Federal Reserve's Office of Inspector General (OIG) reportedly committed to reviewing the Trump Administration's efforts to eliminate the vast majority of CFPB employees and agency contracts on June 6, 2025. This decision...more

CFPB Seeks to Vacate the Open Banking Rule

The CFPB has requested that a federal district court vacate the Biden-era Open Banking Rule (Rule) in a motion for summary judgment filed on May 30, 2025. The CFPB had previously submitted a status report to the U.S. District...more

U.S. House of Representatives Approves 70 Percent Cut to CFPB Funding

The U.S. House of Representatives has passed an extensive budget reconciliation bill that would reduce the CFPB budget by 70 percent. In a 215-214 vote along party lines, the budget cut first approved by the House Committee...more

CFPB Publishes Additional Proposals to Rescind "Unnecessary" Rules and Regulations

The CFPB continues on its path to rescind what it considers to be unnecessary regulatory guidance, with two additional proposals recently published. First, the agency published an interim final rule on May 16, 2025, to...more

CFPB Continues Efforts to Rescind Multiple Biden-Era Rules

The CFPB has withdrawn its 1) Fair Credit Reporting Act (FCRA)/Regulation V Proposed Rule (Data Broker Rule), 2) Prohibited Terms and Conditions in Agreements for Consumer Financial Products or Services (Regulation AA)...more

CFPB Overdraft and Digital Payment Rules Repealed by Trump Administration

President Donald Trump on May 9, 2025, signed into law measures to eliminate two CFPB rules established under the Biden Administration. The first rule repealed was the CFPB's Overdraft Rule, one aspect of the Biden...more

Jonathan McKernan Nomination for CFPB Director Rescinded; New Nominee Not Yet Named

U.S. Department of the Treasury Secretary Scott Bessent announced on May 9, 2025, that Jonathan McKernan has been selected by President Donald Trump to serve as the Undersecretary of Domestic Finance at the Treasury...more

CFPB Rescinds 67 Guidance Documents

The CFPB announced on May 9, 2025, that nearly 70 guidance documents will be withdrawn after an agency-wide review of documents that violate the Administrative Procedure Act (APA). ...more

CFPB Seeks to Vacate the Medical Debt Rule

The CFPB on April 30, 2025, reached an agreement with lender trade groups to vacate the Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information Rule (the Medical Debt Rule). The joint motion...more

CFPB Seeks Dismissal of Pending UDAAP Examination Manual Litigation

The CFPB on April 30, 2025, filed a joint stipulation to dismiss its appeal pending before the U.S. Court of Appeals for the Fifth Circuit regarding an agency policy that expands the scope of antidiscrimination oversight....more

CFPB Provides Status Update Regarding Buy Now, Pay Later Interpretive Rule

The CFPB announced on May 6, 2025, that it will not prioritize enforcement actions taken on the basis of its Buy Now, Pay Later (BNPL) interpretive rule (89 Fed. Reg. 47,068), which was issued in May 2024....more

House Republicans Seek to Cut 70 Percent of CFPB Funding

The U.S. House Committee on Financial Services on April 30, 2025, voted to approve Republican-backed budget legislation that would eliminate almost all funding to the CFPB. In a 30-22 vote along party lines, the draft...more

CFPB Provides Supervision and Enforcement Reprieve on Small Business Lending Rule

In connection with its regulation titled "Small Business Lending Under the Equal Credit Opportunity Act (Regulation B)," implementing Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, 88 Fed. Reg....more

GAO and OIG to Investigate the CFPB's Recent Staff Reductions

U.S. Sen. Elizabeth Warren (D-Mass.), on behalf of 40 Democratic Senators, wrote a letter to CFPB Acting Director Russell Vought on April 28, 2025, expressing "grave concerns" about the agency's ability to fulfill more than...more

CFPB Credit Card Late Fees Rule Vacated by Texas District Court

On April 15, 2025, Judge Mark T. Pittman of the U.S. District Court for the Northern District of Texas entered an order and final judgment vacating the CFPB's credit card penalty fees rule (the Late Fee Rule). Judge Pittman's...more

CFPB Announces New Supervision and Enforcement Priorities, Then Mass Layoffs Temporarily Halted

CFPB Chief Legal Officer Mark Paoletta on April 16, 2025, issued the CFPB's latest staff memo outlining the agency's supervision and enforcement priorities. ...more

D.C. Circuit Limits Prohibition on CFPB Staff Terminations Pending Appeal

In a per curiam order, a three-judge panel of the U.S. Court of Appeals for the District of Columbia Circuit on April 11, 2025, partially stayed a preliminary injunction halting any attempt to dismantle the CFPB. Judges...more

CFPB Provides Supervision and Enforcement Reprieve on Nonbank Registration Regulation

In connection with its regulation titled Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders (the Nonbank Registration Regulation), the CFPB announced on April 11, 2025, that it "will not prioritize...more

CFPB to Conduct Comprehensive Review of Previously Issued Guidance Documents

The CFPB will begin the process of discontinuing regulatory "guidance" and instead enforce the Administrative Procedure Act's rulemaking process. In a pair of internal memos circulated to all divisions and offices within the...more

CFPB's Overdraft Rule and Big Tech Payment Apps Rule Set for Repeal After Congressional Votes

Among other significant rulemakings that the Consumer Financial Protection Bureau (CFPB) finalized in the waning days of the Biden Administration were 1) an overdraft fees final rule that applies to banks and credit unions...more

McKernan Nomination Awaits Full Senate Consideration; Vote Expected in May

Full Senate consideration for Jonathan McKernan to become director of the Consumer Financial Protection Bureau (CFPB) is not officially scheduled but is expected to take place in May based on recent comments by Senate Banking...more

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