Recently, the U.S. Office of Management and Budget received the CFPB’s Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions, outlining 25 regulatory activities at different stages of the administrative process. The Bureau’s agenda included nine entries at the prerule stage, ten entries at the proposed rule stage, five at the final rule stage, and one set for long-term review and action. The CFPB clarified that the timing of these actions is not binding and may change. In its notice, the CFPB also released a list of completed actions, which included regulatory action taken with respect to the FCRA and the reporting of medical debt, credit card penalty fees, and PACE financing.
On September 19, the U.S. Department of the Treasury issued an Advance Notice of Proposed Rulemaking (ANPRM) seeking public input on the implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. This ANPRM builds upon the Request for Comment on Innovative Methods to Detect Illicit Activity Involving Digital Assets issued by Treasury on August 18, which remains open for comment until October 17, 2025.
The CFPB is considering proposing amendments to Regulation V, which implements the Fair Credit Reporting Act (FCRA), to address concerns related to information furnished to consumer reporting agencies regarding coerced debt. This follows the CFPB’s issuance of an advance notice of proposed rulemaking on December 13, 2024 to solicit information on amending the definitions of “identity theft” and “identity theft report,” as well as other related amendments to Regulation V.
President Trump is asking the Supreme Court to allow him to fire Lisa D. Cook from the Federal Reserve Board.
“This application involves yet another case of improper judicial interference with the President’s removal authority—here, interference with the President’s authority to remove members of the Federal Reserve Board of Governors for cause,” Solicitor General D. John Sauer wrote. (All of the other firings involve situations where Trump fired Democratic members of governing boards of other federal agencies without cause even though the relevant statutes stated that such members could only be fired for cause. The Administration is arguing in the other cases that “for cause” termination limitations violate the “Separation of Powers” provision in the Constitution.)
During our most recent Research Assistant Peer Group meeting, we discussed the Consent Order in New York vs. Roach & Murtha (Consent Order). Specifically, we dug into the New York Department of Financial Services (NYDFS) view of meaningful involvement by attorneys under the Fair Debt Collection Practices Act (FDCPA) in the context of collecting judgments obtained by another firm.
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