CFPB Supervision

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On October 29, 2025, CFPB withdrew its proposed rule titled Registry of Supervised Nonbanks That Use Form Contracts To Impose Terms and Conditions That Seek To Waive or Limit Consumer Legal Protections, which was published on February 1, 2023. The proposed rule would have required nonbanks to submit annual reports on the terms and conditions in their form contracts and on related court or arbitrator decisions on the enforceability of those terms and conditions.… Continue Reading

Effective October 27, 2025, the CFPB rescinded the amendments to the Procedures for Supervisory Designation Proceedings that it adopted in April 2022, November 2022, and April 2024, , with the exception of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

Section 1024(b)(7) of the Consumer Financial Protection Act authorizes the CFPB to “prescribe rules to facilitate supervision” of the nonbank covered persons described in section 1024(a), i.e.,… Continue Reading

We recently wrote about the August 15th D.C. Circuit Court of Appeals decision in the lawsuit brought by the labor unions representing CFPB employees against Acting Director Russell Vought. The unions sought injunctive relief in response to what they described as an attempted “shutdown” of the Bureau.

In a 2–1 ruling, the Court of Appeals vacated a preliminary injunction issued by the District Court.… Continue Reading

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 CFPB supervises in the auto finance, international money transfer, debt collection, and consumer credit reporting markets. An agency spokesperson told Law 360, “As part of President Trump’s overhaul of this abusive agency, ‘Larger Participant’ regulations are open for re-examining after more than a decade.… Continue Reading

Our podcast show being released today is Part 2 of our two-part series featuring two former CFPB senior officers who were key employees in the Enforcement Division under prior directors: Eric Halperin and Craig Cowie. Eric Halperin served as the Enforcement Director at the CFPB from 2010 until former Director, Rohit Chopra, was terminated by President Trump.… Continue Reading

Our podcast shows being released today and next Wednesday, June 18 feature two former CFPB senior officers who were key employees in the Enforcement Division under prior directors: Eric Halperin and Craig Cowie. Eric Halperin served as the Enforcement Director at the CFPB from 2010 until former Director, Rohit Chopra, was terminated by President Trump.… Continue Reading

Our podcast show being released today features two former CFPB senior officers who were key employees in the Supervision Division under prior directors: Peggy Twohig and Paul Sanford. Peggy was a founding executive of the CFPB when the agency was created in 2010 and led the development of the first federal supervision program over nonbank consumer financial companies.… Continue Reading

President Trump has signed a resolution nullifying the rule implementing the CFPB’s power to supervise large nonbank financial services providers of general-use digital consumer payment applications.

Trump signed the resolution under the Congressional Review Act, which grants Congress and the President the power to nullify agency rules. The resolution passed the House and Senate before being sent to Trump.… Continue Reading

The podcast we are releasing today is part 1 of a re-purposed webinar we produced on March 25 titled “The Impact of the Election on the CFPB – Part 4.” As a result of the diminishing impact of the CFPB on enforcing the consumer financial services laws, we expect that void to be filled by state government enforcement agencies and private civil litigation, including class and mass actions.… Continue Reading

The Trump Administration has appealed an order by a federal District Court Judge blocking the CFPB from firing 1483 employees effective in June 2025 and cutting off their access to CFPB work systems on April 18, 2025.

Judge Amy Berman Jackson of the U.S. District Court for the District of Columbia last week barred the CFPB from dramatically reducing its staffing, saying she is concerned that CFPB officials are ignoring her earlier order, as modified by the D.C.… Continue Reading