On July 21, 2025, the CFPB announced that it was withdrawing its planned recission of Section 1082.1 of the Consumer Financial Protection Act (CFPA) implementing regulations, which contains procedures by which state officials must notify the CFPB prior to taking an action enforcing the federal CFPA. Specifically, Section 1082.1 requires state attorneys general and other state officials notify the CFPB “at least ten calendar days prior to initiating any action against any covered person” which involves “any provision of title X of the Dodd-Frank Act or any regulation prescribed thereunder.” The regulation also provides the required contents of the state notice to the CFPB.
As Goodwin previously discussed, the original notice, published on May 21, 2025 (the “May 2025 Notice”), stated that the CFPB was seeking comment on a direct final rulemaking which would have gone into effect on July 21, 2025 “unless significant adverse comments [were] received by June 20, 2025.” In response to the May 2025 notice, several consumer and industry groups, including the Association of Credit and Collection Professionals, the Consumer Data Industry Association, the Online Lenders Alliance, and the Professional Background Screening Association, submitted comments asking the Bureau to reconsider its decision to rescind the notification requirements.
In response, on July 21, CFPB withdrew its proposed recission, citing the “significant adverse comments” received. The Bureau signaled that further proposed rulemaking may be forthcoming in light of the comments received.
[View source.]
