The Consumer Financial Protection Bureau plans to pursue 20 rulemaking actions through the end of this year, including a proposed rule reconsidering the larger participant test that defines which debt collectors fall under the Bureau’s supervisory authority, according to its latest regulatory agenda released July last week.
The agenda, published as part of the federal government’s Unified Agenda of Regulatory and Deregulatory Actions, is technically the Fall 2025 edition. Its publication was delayed, and the preamble states it reflects developments only through Jan. 13, 2026. That means some items listed as pending, including the Section 1071 small business lending reconsideration and Regulation B amendments under the Equal Credit Opportunity Act, have already been issued.
For the credit and collection industry, the most consequential item is the proposed rule reconsidering the larger participant test for the consumer debt collection market, anticipated in September. The rulemaking follows an advance notice of proposed rulemaking issued in August 2025 and could redraw the boundaries of CFPB supervision over nonbank collectors. Parallel proposals covering the consumer reporting, automobile financing, and international money transfer markets are expected on the same timeline.
The volume of activity is notable given the Bureau’s reduced workforce and budget. A lawsuit challenging proposed workforce reductions remains pending in federal district court in Washington, D.C., where a temporary stay was granted to allow Brian Johnson, if confirmed as CFPB Director, to review the planned cuts. Even under the reduction plan, the Bureau intends to keep 125 staff members in its Research, Monitoring and Regulations Division, second only to the Operations Division, a signal that rulemaking will remain a central policy tool.
Most items on the agenda are deregulatory. The Bureau plans proposed rules reconsidering the payday lending rule and the Section 1033 open banking rule, both anticipated this month, along with procedural rules governing guidance documents and periodic review of its own regulations. Nine items sit at the final rule stage, including a mortgage servicing rule under Regulation X expected in August and the rescission of pandemic-era mortgage protections.
What is missing may be just as telling. The agenda contains no major new substantive consumer protection initiatives, and despite Acting Director Russell Vought’s stated interest in examining supervised entities for evidence of debanking, no debanking item appears.
