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ARTICLE · 19 NOVEMBER 2025

CFPB Restores CSI Treatment Of "Pose Risk" Decisions

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Effective October 27, 2025, the CFPB rescinded the amendments to the Procedures for Supervisory Designation Proceedings that it adopted in April 2022, November 2022, and April 2024...

United StatesFinance and Banking
Kristen Larson
Kristen Larson
John L. Culhane, Jr.
John L. Culhane, Jr.
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Effective October 27, 2025, the CFPB rescinded the amendments to the Procedures for Supervisory Designation Proceedings that it adopted in April 2022, November 2022, and April 2024, , with the exception of some limited process adjustments.

Section 1024(b)(7) of the Consumer Financial Protection Act authorizes the CFPB to "prescribe rules to facilitate supervision" of the nonbank covered persons described in section 1024(a), i.e., those that are deemed to have engaged in or to be engaging in conduct that poses risks to consumers, as well as to facilitate the "assessment and detection of risks to consumers." In 2013, the CFPB issued procedural rules to govern these supervisory designation proceedings, under which information regarding the proceedings was treated as confidential supervisory information and not publicly disclosed. Those rules were codified at 12 C.F.R. Part 1091. In April 2022, November 2022, and April 2024, the CFPB issued a series of rules

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