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ARTICLE · 11 AUGUST 2025

CFPB Seeks Comment On Proposed Rules To Scale Back Larger Participant Thresholds

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Four advance notices of proposed rulemaking scheduled for publication on August 8 will solicit public comment on whether the CFPB should raise the size thresholds...

United StatesFinance and Banking
A.J. Dhaliwal
A.J. Dhaliwal
Mehul Madia
Mehul Madia
Beineng Zhang
Beineng Zhang
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Four advance notices of proposed rulemaking scheduled for publication on August 8 will solicit public comment on whether the CFPB should raise the size thresholds that determine which nonbank entities qualify as "larger participants" subject to routine Bureau supervision. The notices address the automobile-financing, international money-transfer, consumer-reporting, and consumer debt-collection markets.

Each of the applicable larger participant rules—adopted between 2012 and 2015 under the Consumer Financial Protection Act—sets a threshold based on origination volume or annual receipts. The CFPB is now considering whether those thresholds may sweep in too many small and midsize firms, thereby diverting limited supervisory resources from the largest market participants.

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