The Consumer Financial Protection Bureau has released its Semiannual Regulatory Agenda covering the period from January 2026 through November 2026. Published through the Office of Information and Regulatory Affairs (OIRA) as part of the Unified Agenda of Federal Regulatory and Deregulatory Actions, the agenda provides an important roadmap of the Bureau’s anticipated regulatory activity during the remainder of the year. It should be noted, however, that this is actually the Fall 2025 agenda (its publication was apparently delayed) and the preamble to the agenda states that it reflects developments only through January 13, 2026. As a result, three of the nine final rule actions listed on the agenda address rulemaking actions that were issued after January 13, 2026. Those are: 1. Financial Data Transparency Act; 2. Reconsideration of Section 1071 Small Business Lending Data Collection Rule; and 3. Amendments to Regulation B Under the Equal Credit Opportunity Act.

What is perhaps most striking is not the substance of any single rulemaking, but the sheer number of actions on the agenda. Despite the CFPB’s substantially reduced workforce and budget under the Trump Administration, the Bureau has identified 20 rulemaking actions that it expects to pursue in addition to five lone term actions. (Short descriptions by the CFPB, which are referred to as “abstracts,” of each rulemaking item on the agenda appear with the agenda.) While many of these initiatives are deregulatory in nature, the agenda demonstrates that rulemaking remains a central policy tool for the Bureau. We note, in the lawsuit before the D.C. federal district court challenging the proposed CFPB workforce reductions, at the request of the National Treasury Employees Union and CFPB the court granted a temporary stay to provide time for Brian Johnson, if confirmed as CFPB Director, to review the planned reductions. While the CFPB proposes significant reductions in staff overall, it plans to retain 125 staff members in the Research, Monitoring and Regulations Division, second only to the planned 133 staff members in the Operations Division. This reflects that the CFPB intends to be active with rulemaking.

Three Prerule Actions

The agenda identifies three matters in the prerule stage:

  • Amendments to Dodd-Frank Act Sections 1031 and 1036 (RIN 3170-AA88);
  • Ability-to-Repay/Qualified Mortgages (RIN 3170-AB35); and
  • Prepaid Accounts Under Regulations E and Z (RIN 3170-AB55).

The inclusion of these items indicates that the Bureau is in the earliest stages of considering potential amendments to several significant regulations that have long affected the consumer financial services industry.

Eight Proposed Rulemakings

The proposed rule stage reflects the Bureau’s continued emphasis on reconsidering existing regulations and establishing procedural safeguards governing its own regulatory process.

The agenda includes proposed rules involving:

  • Reconsideration of the Payday Lending Rule;
  • Reconsideration of the Personal Financial Data Rights or open banking (Section 1033) Rule;
  • Procedures for Guidance Documents;
  • Procedures for Periodic Review of Bureau Regulations;
  • Larger Participant Rules covering the automobile finance, debt collection, consumer reporting, and international money transfer markets; and
  • Contingency Calculations for Determining the Average Prime Offer Rate.

One notable development is the Bureau’s continued effort to revisit the larger participant rules that define the scope of CFPB supervisory authority over nonbank financial companies in several important markets.

Nine Final Rule Actions

The final rule stage contains nine actions, including several significant reconsideration and rescission efforts:

  • Streamlining Mortgage Servicing for Borrowers Experiencing Payment Difficulties (Regulation X);
  • Financial Data Transparency Act;
  • Remittance Transfers Under Regulation E;
  • Reconsideration of the Section 1071 Small Business Lending Data Collection Rule;
  • Rescission of the COVID-19 mortgage servicing protections adopted during the pandemic;
  • Rescission of the State Official Notification Rules;
  • Amendments to Regulation B under the Equal Credit Opportunity Act; and
  • Amendments to the Consumer Financial Civil Penalty Fund Rule.

Several of these items reflect the Bureau’s continuing effort to unwind regulations adopted during the Chopra Administration or to revise procedural rules governing the CFPB’s supervisory and enforcement authorities. Nevertheless, the inclusion of the mortgage servicing rule under Regulation X is interesting, as it would apparently finalize a rule proposed in July 2024 during Chopra’s tenure as CFPB Director. The proposal was criticized by the industry as it would impose burdensome requirements and many provisions were likely beyond the CFPB’s statutory authority. Additionally, as noted below, the CFPB’s long-term actions include the discretionary mortgage servicing rules under RESPA/Regulation X and TILA/Regulation Z.

Five Long Term Actions

  • Identity Theft and Coerced Debt
  • Rescission of Loan Originator Compensation Requirements under the Truth in Lending Act
  • Discretionary Servicing Rules under the Real Estate Settlement Procedures Act
  • Discretionary Mortgage Servicing Rules under the Truth in Lending Act
  • Loan Originator Compensation Requirements under the Truth in Lending Act

As is typically the case with long term actions, no deadlines were announced for these rulemaking proceedings. (Our understanding is that while the CFPB initially considered rescinding various discretionary provisions in the loan originator compensation rule, it now understands that various discretionary provisions are important to retain and that revisiting the rule in general is a preferable path.)

Key Themes

Several themes emerge from the agenda.

First, the Bureau continues its systematic review of major regulations issued during the previous Administration.

Second, the CFPB is devoting considerable attention to procedural rules that govern how the agency itself operates. New rules concerning guidance documents, periodic review of regulations, supervisory designation proceedings, and state official notification procedures reflect an emphasis on internal governance and administrative process.

Third, the Bureau continues to evaluate the scope of its supervisory authority over nonbank financial companies through revisions to the larger participant rules affecting several markets.

What Is Missing

Equally noteworthy are the items that do not appear on the agenda. The Bureau has not proposed major new substantive consumer protection regulations comparable to those advanced during the Chopra Administration. Instead, the agenda is overwhelmingly focused on reconsidering, rescinding, refining, or streamlining existing regulations.

That shift is entirely consistent with the Bureau’s policy direction over the past year.

It should be noted, however, that the CFPB has very recently notified OIRA that it intends to publish a Request for Information about credit card late fees. See the blog that we recently published about that. Additionally, the CFPB recently issued a request for information on the TILA/RESPA integrated disclosure (TRID) rule, the right to rescind under TILA, and reverse mortgages.

Although Acting Director Vought has indicated that the CFPB will be examining supervised entities to look for evidence of debanking ,there is no item on the agenda related to debanking.

Looking Ahead

The Unified Agenda is not binding, and rulemaking schedules frequently change. Nevertheless, the agenda offers the best available indication of the CFPB’s regulatory priorities for the coming months.

As we have previously reported, President Trump has nominated Brian Johnson to be the next Director of the CFPB. Assuming that he is confirmed by the Senate (which we anticipate happening sometime before the end of this month), Mr. Johnson is certain to have a great deal of influence in shaping the regulatory agenda.

For banks, credit unions, fintech companies, mortgage lenders and servicers, consumer reporting agencies, debt collectors, money transmitters, and other participants in the consumer financial services industry, the agenda confirms that the Bureau’s principal focus will remain the reassessment of existing regulations rather than the adoption of significant new regulatory requirements.

Even with the planned number of staff members in the Research, Monitoring and Regulations Division, it remains to be seen whether all 20 rulemaking initiatives can be completed on the timetable reflected in the agenda. Nevertheless, the agenda demonstrates that the CFPB intends to remain an active regulator and will continue using the rulemaking process to implement the current Administration’s policy objectives.

We will continue to monitor each of these rulemakings and report on significant developments as proposed and final rules are issued.