News & Analysis as of

Consumer Financial Protection Act (CFPA) Regulatory Oversight

Sheppard Mullin Richter & Hampton LLP

In a Retreat, CFPB Submits $145 Million Funding Request Following Court Order

On January 9, CFPB Acting Director Russel Vought submitted a $145 million funding request to Federal Reserve Board Chair Jerome Powell for the CFPB’s second quarter of fiscal year 2026. The notice states the submission was...more

Cooley LLP

CFPB Submits to Court Order, Seeks New Funding

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On January 9, 2026, the Consumer Financial Protection Bureau (CFPB) requested $145 million in new funding from the Federal Reserve....more

Sheppard Mullin Richter & Hampton LLP

CFPB to Begin Transferring Remaining Litigation to DOJ Amid Funding Collapse

On November 20, 2025, the CFPB notified staff that it will begin transferring its remaining enforcement lawsuits and other pending litigation to the Department of Justice. The shift comes as the agency anticipates running out...more

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

Ballard Spahr LLP

CFPB Restores CSI Treatment of “Pose Risk” Decisions

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Effective October 27, 2025, the CFPB rescinded the amendments to the Procedures for Supervisory Designation Proceedings that it adopted in April 2022, November 2022, and April 2024, , with the exception of some limited...more

Sheppard Mullin Richter & Hampton LLP

CFPB Terminates 2023 Consent Order Against a National Consumer Reporting Agency for Alleged Security Freeze Violations

On November 3, 2025, the Consumer Financial Protection Bureau terminated its 2023 consent order against a national consumer reporting agency. The original order, issued in October 2023, required more than three million...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

Patomak Global Partners

Understanding the New De-Banking Executive Order

Situation Overview: On August 7, 2025, President Trump issued an Executive Order (the “Order”) entitled “Guaranteeing Fair Banking for All Americans”, which has implications for retail and institutional fair lending...more

Holland & Knight LLP

CFPB Rescinds Amendments to Supervisory Designation Proceedings

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The CFPB on Sept. 25, 2025, issued a final rule to rescind amendments it previously adopted to the Procedures for Supervisory Designation Proceedings, "with the exception of some limited process adjustments."...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

Foley & Lardner LLP

Consumer Financial Protection Bureau Proposes New Rules Reducing Regulatory Burdens on Consumer Reporting Agencies

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The Consumer Financial Protection Bureau (the “Bureau”) recently announced two new interpretive rules that, if implemented, will significantly reduce regulatory burdens on many consumer reporting agencies (CRAs)....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

Sheppard Mullin Richter & Hampton LLP

CFPB Secures Permanent Ban on Fintech Service Provider for Alleged Unfair Practices

On August 21, the CFPB filed a complaint and stipulated final judgment in the U.S. Bankruptcy Court for the Central District of California against a fintech service provider in Chapter 11 proceedings. The Bureau alleged...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

AI in the Financial Services Industry

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The recent American Association of Residential Mortgage Regulators Annual Conference included a presentation highlighting the rising use of Artificial Intelligence (“AI”) in the Financial Services industry. As this will...more

Troutman Pepper Locke

CFPB Will Not Reissue Medical Debt Advisory Opinion

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On July 14, the Consumer Financial Protection Bureau (CFPB or Bureau) filed a status report announcing its decision not to reissue its Medical Debt Collection Advisory Opinion, which had been issued in 2024 to “remind debt...more

Orrick, Herrington & Sutcliffe LLP

Senate Banking Committee proposes to reduce CFPB’s funding to zero

On June 6, the Senate Banking, Housing, and Urban Affairs Committee released its proposed amendment to H.R. 1, the “One Big Beautiful Bill Act,” which included a proposed reduction in the amount of funds the CFPB can annually...more

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