On July 21, the CFPB withdrew its plan to repeal rules that provide procedures for state officials to notify the Bureau before initiating enforcement actions under the Consumer Financial Protection Act (CFPA). The CFPB cited “significant adverse comments” as the reason for the withdrawal and indicated it will consider the feedback in a subsequent rulemaking.
The notification rules, first adopted in 2012, require state attorneys general and regulators to inform the CFPB at least 10 days before filing an action to enforce federal consumer financial protection laws. The notice must include the parties involved, factual allegations, and a copy of the complaint. The now-withdrawn rule would have repealed these requirements in full. Several industry trade groups pushed back against the proposal, arguing that the rules promote consistent enforcement, prevent duplicative litigation, and provide clarity about states’ use of shared enforcement authority under the Consumer Financial Protection Act.
In its May 2025 proposal, the CFPB said the rules were no longer necessary because they merely restated what is already required under the statute. The Bureau viewed the notice procedures as an unnecessary layer of regulation that increased compliance costs without providing meaningful additional benefit.
Putting It Into Practice: While the agency may still pursue changes through a standard rulemaking process, the current rules remain in effect for now. State officials and financial institutions should continue to follow existing notice requirements and monitor for future updates that could affect the timing, scope, or content of state-level enforcement disclosures under the Consumer Financial Protection Act.