CFPB Issues Deregulatory Agenda For Measures Under Consideration Through May 2026

Last week, the CFPB published its long-awaited Spring 2025 Unified Agenda, which outlines 24 regulatory items the Bureau intends to consider over the next nine months. The efforts largely focus on updating projects, reconsidering rulemakings, and adding limited new initiatives. Many of the included actions would roll back or rescind Biden-era rulemakings or those finalized under previous CFPB Directors.

Among the most notable activities is a proposed rule that would reconsider provisions of the 2017 rule on Payday, Vehicle, Title, and Certain High-Cost Installment Loans. This rule was issued by the CFPB in October 2017 and became effective in January 2018. When first issued, it identified “as an unfair and abusive practice for a lender to make [short-term and longer term loans with balloon payments] without reasonably determining that consumers have the ability to repay the loans according to their terms.” It also identified it as an “unfair and abusive practice to attempt to withdraw payment from a consumer’s account after two consecutive payment attempts have failed, unless the lender obtains the consumer’s new and specific authorization to make future withdrawals from the account” for those same loans as well as longer-term loans with an Annual Percentage Rate greater than 36 percent that are repaid directly from the consumer’s account. The mandatory underwriting provisions were previously revoked via a final rule in July 2020.

Other anticipated rulemakings include actions on small business lending and personal data rights, in addition to formally rescinding the rule creating a registry of nonbank entities subject to final public orders issued by a government agency in connection with the offering or provision of a consumer financial product. In April, the Bureau announced that it would not prioritize enforcement or supervision activities with regard to this registry.