On July 21, 2025, the CFPB
announced that it was withdrawing its planned recission of
Section 1082.1 of the Consumer Financial Protection Act (CFPA)
implementing regulations, which contains procedures by which state
officials must notify the CFPB prior to taking an action enforcing
the federal CFPA. Specifically, Section 1082.1 requires state
attorneys general and other state officials notify the CFPB
"at least ten calendar days prior to initiating any action
against any covered person" which involves "any provision
of title X of the Dodd-Frank Act or any regulation prescribed
thereunder." The regulation also provides the required
contents of the state notice to the CFPB.
As Goodwin previously
discussed, the original
notice, published on May 21, 2025 (the "May 2025
Notice"), stated that the CFPB was seeking comment on a direct
final rulemaking which would have gone into effect on July 21, 2025
"unless significant adverse comments [were] received by June
20,