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ARTICLE · 24 SEPTEMBER 2025

CFPB Withdraws Plan To Rescind Rules Detailing Procedures For State Actions Under The Dodd-Frank Act

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A decrease in Consumer Financial Protection Bureau ("CFPB" or "Bureau") enforcement activity may motivate state regulators to fill the enforcement void, including by bringing actions...

United StatesConsumer Protection
Christa Bieker
Christa Bieker
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A decrease in Consumer Financial Protection Bureau ("CFPB" or "Bureau") enforcement activity may motivate state regulators to fill the enforcement void, including by bringing actions under the Dodd-Frank Act. Earlier this year, as part of its deregulatory efforts, the CFPB issued a direct final rule rescinding procedures by which a state official must notify the Bureau when the official takes an action to enforce the Dodd-Frank Act. Because of comments the Bureau received in response to the rule, the CFPB has withdrawn its plan to rescind these notification procedures.

State Authority to Bring Actions Under the Dodd-Frank Act

With some limitations on actions against national banks or federal savings associations, Section 1042 of the Dodd-Frank Act provides that state attorneys general may bring a civil action to enforce Title X of the Dodd-Frank Act or regulations issued under Title X of the Dodd-Frank Act.1 Similarly, Section 1042 provides that a state regulator

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