What New CFPB Oversight Limits Would Mean for 4 Markets

Financial Services attorney Eamonn Moran and litigation attorney Ashley Feighery co-authored a Law360 article analyzing the Consumer Financial Protection Bureau's (CFPB) four advance notices of proposed rulemaking (ANPRMs) that would narrow which nonbank "larger participants" fall under CFPB supervision in the automobile financing, international money transfer, consumer reporting and consumer debt collection markets. The authors explain how raising thresholds (e.g., originations, transfer volumes and annual receipts) could substantially reduce the number of supervised entities while still covering a large share of market activity, aligning with the bureau's stated plan to concentrate resources and cut supervisory events. They also outline proposal options under consideration in each market, the agency's policy rationale (compliance burdens versus benefits and market concentration), and key considerations for stakeholders preparing comments before the Sept. 22, 2025, deadline.

Holland & Knight maintains a resource center, CFPB Dispatch: Legal Updates and Insights, on the latest CFPB developments. Mr. Moran and Ms. Feighery have contributed a number of articles or interviews to this repository.

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