On September 4, the CFPB published its Spring 2025 Unified Agenda on the Office of Information and Regulatory Affair's website. The agenda identifies 24 regulatory items across the final, proposed, and prerule stages, covering a wide range of consumer finance issues.
The Bureau explained in a notice that this agenda covers the period from June 2025 through May 2026 and focuses primarily on updating projects from the Fall 2024 agenda, reconsidering recently completed rulemakings, and adding limited new initiatives. These include potential rulemakings on unfair, deceptive, or abusive acts and practices, adjustments to larger participant thresholds, and other actions to recalibrate existing regulatory frameworks.
The agenda groups these 24 items into three stages of rulemaking, including:
- Final rule stage. The Bureau is finalizing amendments to mortgage servicing under Regulation X, new requirements under the Financial Data Transparency Act, and changes to remittance transfers under Regulation E.It is also rescinding COVID-era mortgage protections and retaining state official notification procedures.
- Proposed rule stage. The Bureau plans to rescind the nonbank registry and adjudication rules, revise supervision designation proceedings, and reconsider the payday lending, open banking, and small business lending rules.Other proposals cover guidance procedures, periodic regulatory review, and standards for supervisory designations and ECOA disparate impact.
- Prerule stage. Early initiatives included a rule defining the boundaries of UDAAP, proposals on coerced debt and identity theft under Regulation V, rescission of loan originator compensation requirements, new discretionary servicing rules, and larger participant threshold reviews in several consumer finance markets.
Putting It Into Practice: The Spring 2025 agenda reflects the Bureau's recalibration under new leadership, with several items already advancing since April, including changes to nonbank supervision, designation standards, state enforcement notifications, and larger participant thresholds (previously discussed here, here, here, and here). The CFPB has already taken multiple steps to scale back rules adopted under prior leadership, and this agenda signals that deregulatory activity is likely to continue. At the same time, state regulators are advancing their own enforcement and legislative agendas, so overall compliance obligations remain significant.Financial institutions and fintech companies should monitor developments at both levels and engage in the rulemaking process to help shape the Bureau's evolving framework.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
