News & Analysis as of

Comment Period Consumer Financial Protection Bureau (CFPB)

Hudson Cook, LLP

CFPB Proposes Legal Standard for Nonbank Supervision Proceedings

Hudson Cook, LLP on

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

Saul Ewing LLP

Open Call: CFPB Seeks Comments on New Section 1033 Open Banking Rule

Saul Ewing LLP on

The first step in the future of open banking under the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank" or the "Act") is here: in a notice posted August 22, 2025 (the "Notice"), the Consumer Financial...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

Holland & Knight LLP

CFPB Seeks Comments and Data on Revised Open Banking Rule

Holland & Knight LLP on

The CFPB published an advanced notice of proposed rulemaking (ANPR) on Aug. 22, 2025, seeking comments and data to aid in the agency's reconsideration of its Section 1033 Open Banking Rule. This notice follows the CFPB's...more

Morgan Lewis

CFPB Invites Comment on Larger Participant Thresholds

Morgan Lewis on

The Consumer Financial Protection Bureau has issued advance notices of proposed rulemaking seeking public comment on whether to revise the thresholds that define “larger participants” in key consumer financial industries....more

Troutman Pepper Locke

CFPB Releases New Advance Notice of Proposed Rulemaking on Section 1033 Open Banking Rule

Troutman Pepper Locke on

On August 21, the Consumer Financial Protection Bureau (CFPB or Bureau) took a significant step forward in its reconsideration of the Section 1033 open banking final rule, originally issued in November 2024, by issuing an...more

Troutman Pepper Locke

CFPB Proposes Rules Re-Defining Larger Participants in Multiple Markets

Troutman Pepper Locke on

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

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – August 2025 # 2

Troutman Pepper Locke on

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

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

Venable LLP

CFPB Reviewing Automobile Financing Larger Participant Rule

Venable LLP on

The Consumer Financial Protection Bureau (CFPB) is inviting comment on whether the 2015 larger participant rule for automobile financing remains the right measure of market significance. Comments are due September 22, 2025....more

Venable LLP

CFPB Reviewing Consumer Reporting Larger Participant Rule

Venable LLP on

The Consumer Financial Protection Bureau (CFPB) is inviting comment on whether its 2012 "larger participant" rule for the consumer reporting market continues to capture the most significant market actors in light of industry...more

Venable LLP

CFPB Reviewing Debt Collection Larger Participant Rule

Venable LLP on

The Consumer Financial Protection Bureau (CFPB) is inviting comment on whether its "larger participant" rule for the consumer debt collection market, in place since 2012, should be updated to reflect changes in the market and...more

Venable LLP

CFPB Reviewing International Money Transfer Larger Participant Rule

Venable LLP on

The Consumer Financial Protection Bureau (CFPB) is inviting comment on whether the 2014 larger participant rule for international money transfers should be revised to better reflect market conditions and supervisory...more

Wiley Rein LLP

Wiley Consumer Protection Download (August 12, 2025)

Wiley Rein LLP on

Federal and State Regulatory Announcements- CFPB Seeks Comment on New Thresholds for Larger Participants in the Automobile Financing, Consumer Reporting, International Money Transfer, and Debt Collection Markets. On August...more

Holland & Knight LLP

CFPB Seeks Comments on Increased Larger Market Participant Thresholds in 4 Key Markets

Holland & Knight LLP on

The CFPB published four advanced notices for proposed rulemaking in the Federal Register on Aug. 8, 2025. Each notice seeks comment from experts within the automobile financing, international money transfer, consumer...more

Orrick, Herrington & Sutcliffe LLP

CFPB publishes four ANPRs seeking comment on the definitions of “larger participants” in specific supervised industries

On August 8, the CFPB published four advance notices of proposed rulemaking in the Federal Register seeking public comment to reconsider the test for defining larger participants in the consumer reporting, debt collection,...more

Sheppard Mullin Richter & Hampton LLP

CFPB Seeks Comment on Proposed Rules to Scale Back Larger Participant Thresholds

Four advance notices of proposed rulemaking scheduled for publication on August 8 will solicit public comment on whether the CFPB should raise the size thresholds that determine which nonbank entities qualify as “larger...more

Orrick, Herrington & Sutcliffe LLP

CFPB requests comment on its consumer complaint intake form

On May 22, the CFPB published a notice in the Federal Register requesting comments on the extension of the Consumer Complaint Intake System Company Portal Boarding Form. The Dodd-Frank Act requires the CFPB to facilitate the...more

Ballard Spahr LLP

CFPB proposes to rescind rule requiring nonbanks to register certain agency enforcement and court orders

Ballard Spahr LLP on

The CFPB is proposing to rescind its rule that requires certain nonbank entities to register covered agency enforcement and court orders....more

Orrick, Herrington & Sutcliffe LLP

CFPB proposes to rescind amendments to nonbank supervision

On May 14, the CFPB published a Federal Register notice withdrawing its proposed rule on the Procedures for Supervisory Designation Proceedings. These amendments were each codified in 12 C.F.R. 1091. As previously covered by...more

Orrick, Herrington & Sutcliffe LLP

CFPB proposes to rescind its nonbank registry rule

On May 14, the CFPB published a Federal Register notice withdrawing its proposed rule requiring nonbanks to report the existence of an order and file annual compliance reports where such nonbanks were subject to certain final...more

Bradley Arant Boult Cummings LLP

CFPB Rescinding the 2021 COVID-19 Mortgage Servicing Final Rule

On May 15, 2025, the Consumer Financial Protection Bureau (CFPB) filed an interim final rule in the Federal Register that will rescind its prior 2021 COVID-19 mortgage servicing final rule. The interim final rule is set for...more

Troutman Pepper Locke

CFPB Proposes Rescission of Nonbank Registration Rule

Troutman Pepper Locke on

Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) released a proposed rule to rescind its previous regulation requiring nonbank entities to report certain agency and court orders to a Bureau registry....more

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