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Consumer Financial Protection Act (CFPA) Proposed Rules

Ballard Spahr LLP

CFPB rescinds amendments to the Rules of Practice for Adjudication Proceedings

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Effective October 29, 2025, the CFPB finalized its rule, published at 90 Fed. Reg. 48737-60, rescinding certain amendments to the rules made on February 22, 2022 and on March 29, 2023 (collectively, the 2022 and 2023...more

Troutman Pepper Locke

CFPB’s Proposed Reg B Overhaul: Ending ECOA Disparate Impact, Narrowing Discouragement, and Reshaping SPCPs

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The Consumer Financial Protection Bureau (CFPB or Bureau) has proposed an unprecedented, far‑reaching rewrite of Regulation B (Reg B) under the Equal Credit Opportunity Act (ECOA). If finalized, the proposed rule would...more

Orrick, Herrington & Sutcliffe LLP

Twenty state attorneys general submit joint letter to CFPB

On September 25, 20 state attorneys general submitted comments on a newly proposed rule by the CFPB that would redefine the legal standard for supervisory designation proceedings. ...more

Troutman Pepper Locke

The 1033 Shake-Up: CFPB's New Rulemaking Adventure — The Consumer Finance Podcast

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In this crossover episode of Payments Pros and The Consumer Finance Podcast, Carlin McCrory is joined by colleague Kim Phan to discuss the Consumer Financial Protection Bureau's (CFPB) recent developments regarding Section...more

Troutman Pepper Locke

The 1033 Shake-Up: CFPB's New Rulemaking Adventure — Payments Pros – The Payments Law Podcast

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In this episode of Payments Pros, Carlin McCrory is joined by colleague Kim Phan to discuss the Consumer Financial Protection Bureau's (CFPB) recent developments regarding Section 1033 of the Consumer Financial Protection Act...more

Orrick, Herrington & Sutcliffe LLP

CFPB publishes its unified agenda for spring 2025

Recently, the U.S. Office of Management and Budget received the CFPB’s Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions, outlining 25 regulatory activities at different stages of the administrative process. ...more

Bradley Arant Boult Cummings LLP

Keeping the Scalpel Sharp: The CFPB’s Proposal in the Larger Arc of Second-Term Trump Deregulation

The Consumer Financial Protection Bureau’s (CFPB) latest proposed rule to define risks to consumers may appear technical, but its implications reach far beyond the narrow mechanics of supervisory designation. By binding...more

Ballard Spahr LLP

CFPB proposes to standardize Nonbanks’ ‘Risks to Consumers’

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The CFPB is proposing a rule that standardizes determinations that nonbanks pose “risks to consumers,” a move that could result in fewer nonbanks being designated as posing risk and thus subject to CFPB supervisory...more

Bradley Arant Boult Cummings LLP

CFPB Focuses on “Serious Conduct” with Proposed Limits on Nonbank Supervision

On August 26, 2025, the Consumer Financial Protection Bureau (CFPB or the Bureau) published a proposed rule that would narrow its supervisory authority over nonbanks. Under the proposed rule, the CFPB plans to exercise...more

Cadwalader, Wickersham & Taft LLP

Summer’s Over and the Regulations Keep Coming, September 2025 - End of Summer Regulatory Round-Up

As summer comes to an end, here is a round-up of regulatory activities in financial services: Consumer Financial Protection Bureau Sues Synapse. The fintech filed for bankruptcy in April 2024 has been sued by the CFPB on...more

Cooley LLP

CFPB Narrows Its Supervision of Nonbanks

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On Tuesday, August 26, the Consumer Financial Protection Bureau (CFPB) announced a proposed rule that would likely decrease the number of nonbanks it supervises under Section 1024(a)(1)(C) of the Consumer Financial Protection...more

Hudson Cook, LLP

CFPB Proposes Legal Standard for Nonbank Supervision Proceedings

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On August 26, 2025, the Consumer Financial Protection Bureau published a proposed rule in the Federal Register that would define "risks to consumers" and bind the Bureau in proceedings to designate nonbanks for Bureau...more

Orrick, Herrington & Sutcliffe LLP

CFPB proposes rule clarifying supervisory designation standard for nonbanks

On August 26, the CFPB issued a proposed rule to clarify the legal standard when determining whether to designate a nonbank covered person for Bureau supervision under Section 1024(a)(1)(C) of the CFPA. The proposal would...more

Sheppard Mullin Richter & Hampton LLP

CFPB Proposes Rule Narrowing Nonbank Supervisory Authority Under CFPA

On August 26, 2025, the CFPB published a notice of proposed rulemaking to narrow the scope of its authority to designate nonbanks for supervision under the Consumer Financial Protection Act (CFPA). The proposal follows...more

Troutman Pepper Locke

CFPB Proposes Stricter Standards Limiting Supervision of Nonbanks

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The Consumer Financial Protection Bureau (CFPB or Bureau) is taking a significant step to modify its supervisory approach to nonbanks by publishing a proposed rule advancing a more stringent definition of “risks to consumers”...more

Holland & Knight LLP

CFPB Proposes Legal Standard Applicable to Supervisory Designation Proceedings

Holland & Knight LLP on

The CFPB on Aug. 26, 2025, issued a proposed rule to adopt a legal standard applicable to supervisory designation proceedings. Specifically, the CFPB is proposing to adopt a standard definition of "risks to consumers with...more

Troutman Pepper Locke

CFPB Proposes Rules Re-Defining Larger Participants in Multiple Markets

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On August 8, the Consumer Financial Protection Bureau (CFPB or Bureau) published a series of proposed rules aimed at redefining what constitutes a “larger participant” in several key financial markets. Under § 1024 of the...more

Ballard Spahr LLP

CFPB Seeks Comments On Raising ‘Larger Participant’ Thresholds

Ballard Spahr LLP on

On August 8, 2025, the Consumer Financial Protection Bureau (“CFPB”) issued four advance notices of proposed rulemaking (“ANPR”) inviting comments on whether it should substantially reduce the number of nonbank companies the...more

Goodwin

CFPB Abandons Plan to Scrap State Notice Rule

Goodwin on

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...more

Sheppard Mullin Richter & Hampton LLP

CFPB Withdraws Rule to Eliminate State Enforcement Notification Requirements

On July 21, the CFPB withdrew its plan to repeal rules that provide procedures for state officials to notify the Bureau before initiating enforcement actions under the Consumer Financial Protection Act (CFPA). The CFPB cited...more

Sheppard Mullin Richter & Hampton LLP

CFPB Proposes to Eliminate Education Allocations from Civil Penalty Fund

On June 18, the CFPB published a proposed rule that would rescind its authority to use money from the Civil Penalty Fund for consumer education and financial literacy initiatives. The proposed changes would amend the CFPB’s...more

Holland & Knight LLP

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

Holland & Knight LLP on

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

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – May 2025 # 3

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more

Orrick, Herrington & Sutcliffe LLP

CFPB issues new proposal to ban certain financial contract terms

On January 13, the CFPB proposed a new rule to ban large banks and consumer finance companies from using certain contractual provisions in agreements with consumers under Regulation AA. The CFPB’s proposal warns against the...more

Sheppard Mullin Richter & Hampton LLP

CFPB Proposes Rule to Protect Consumers from Unfair Contract Clauses

On January 13, 2025, the CFPB announced a proposed rule aimed at prohibiting companies from including in consumer agreements terms that operate to waive consumers’ legal rights, allow companies to unilaterally change key...more

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