News & Analysis as of

Consumer Financial Protection Act (CFPA) Risk Management Rulemaking Process

Ballard Spahr LLP

CFPB Restores CSI Treatment of “Pose Risk” Decisions

Ballard Spahr LLP on

Effective October 27, 2025, the CFPB rescinded the amendments to the Procedures for Supervisory Designation Proceedings that it adopted in April 2022, November 2022, and April 2024, , with the exception of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

Ballard Spahr LLP

CFPB proposes to standardize Nonbanks’ ‘Risks to Consumers’

Ballard Spahr LLP on

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

Troutman Pepper Locke

CFPB Proposes Stricter Standards Limiting Supervision of Nonbanks

Troutman Pepper Locke on

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

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