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Quick analysis: Everything is back up again

After a dip in most statute filings last month, everything is back up in July.

TCPA (+6.2%), FDCPA (+4.9%) and FCRA (+18.9%(!)) were all up for the month of July. YTD, TCPA (+52.7%) and FCRA (+23%) are both way up, while FDCPA (-5.3%) is the only one still lagging behind last year. But even that margin shrunk (by -.6%) last month, following a months-long pattern of getting smaller.

We have previously blogged about the August 15 DC Circuit Court opinion in the lawsuit filed months ago by the labor unions representing CFPB Employees against the Acting Director of the CFPB, Russell Vought, seeking injunctive relief related to the alleged “shut down” of the agency. As reported, the Court of Appeals, by a 2-1 majority, vacated a preliminary injunction granted by the District Court which, among other things, had precluded the CFPB from implementing a reduction-in-force (“RIF”) which would have left the CFPB with only 200 employees to perform its statutorily-mandated functions.

The U.S. banking sector is undergoing a seismic regulatory transformation, driven by twin forces: the dismantling of politicized debanking practices and the recalibration of capital requirements for systemically important institutions.

On August 8, 2025, the Consumer Financial Protection Bureau (“CFPB”) issued four advance notices of proposed rulemaking (“ANPR”) inviting comments on whether it should substantially reduce the number of nonbank companies the CFPB supervises in the auto finance, international money transfer, debt collection, and consumer credit reporting markets. An agency spokesperson told Law 360, “As part of President Trump’s overhaul of this abusive agency, ‘Larger Participant’ regulations are open for re-examining after more than a decade.

On August 15, the U.S. Court of Appeals for the District of Columbia issued a decision in the case of National Treasury Employees Union (NTEU) v. Consumer Financial Protection Bureau (CFPB or Bureau). The appellate court vacated the district court’s preliminary injunction, which had previously restricted the CFPB’s actions to halt the Bureau’s operations and terminate its employees.