The Consumer Financial Protection Bureau will continue to require state officials to notify the agency of the enforcement of the Consumer Financial Protection Act.
In an unexpected turn of events, the CFPB reversed its decision to rescind the procedures under which state regulatory officials must notify the CFPB of actions under the act. The CFPB originally proposed to eliminate the rule back in May, stating it was part of the administration’s efforts to roll back unnecessary regulations. But in doing so, the CFPB reserved the option to maintain the rule should the May proposal generate “significant adverse comments.”
In a Federal Register notice published July 21, 2025, the CFPB noted that because significant adverse comments were received, the Bureau is withdrawing the proposal.
It is difficult to predict what type of impact, if any, retaining this reporting obligation will have on states’ opting to exercise their statutory authority to enforce federal consumer financial protection laws.
The rule implementing this obligation has existed for several years, and many states have used the authority when the facts and circumstances of the violation lent themselves to such enforcement action. Likewise, nothing in this development affects individual states’ ability to enforce their separate state-based consumer financial protection laws and regulations.
Independent dealers are encouraged to continue to take their compliance obligations seriously and monitor developments at the state and federal level.
