Banking and Finance Law Daily Wrap Up, REGULATION TRACKER—Upcoming comment deadlines and effective dates, (Nov 3, 2025)

By WK Editorial Staff

Comment deadlines and effective dates for regulatory activity issued by the federal financial institution agencies.

The Banking and Finance Law Daily Regulation Tracker includes a Proposed Rules Comment Calendar and a table of Final Rule Effective Dates. Recent activity includes the following.

The Consumer Financial Protection Bureau has issued an interpretive rule to clarify that the Fair Credit Reporting Act generally preempts state laws that touch on broad areas of credit reporting, consistent with Congress’s intent to create national standards for the credit reporting system. This interpretive rule replaces a July 2022 interpretive rule that the Bureau withdrew in May 2025.

The CFPB has also ended three recent rulemakings. The Bureau issued a final rule to rescind its rule requiring certain types of nonbank covered persons subject to certain final public orders obtained or issued by a government agency in connection with the offering or provision of a consumer financial product or service to report the existence of the orders and related information to a Bureau registry. The CFPB has also rescinded two amendments, issued in 2022 and 2023, to its Rules of Practice for Adjudication Proceedings which are codified at 12 C.F.R. part 1081. The CFPB took this action citing concerns about provisions transferring decision authority from presiding hearing officers to the CFPB Director. Finally, the Bureau withdrew its Notice of Proposed Rule entitled “Registry of Supervised Nonbanks That Use Form Contracts To Impose Terms and Conditions That Seek To Waive or Limit Consumer Legal Protections,” published on Feb. 1, 2023. The Bureau determined that “legislative rulemaking is not necessary or appropriate at this time to address the subject matter of the Proposed Rule.”

The Office of the Comptroller of the Currency is proposing to amend 12 CFR part 30 by rescinding appendix E, OCC Guidelines Establishing Standards for Recovery Planning by Certain Large Insured National Banks, Insured Federal Savings, and Insured Federal Branches. The OCC is taking this action as a part of the ongoing assessment of the agency’s supervisory framework to identify and eliminate unnecessary regulatory burden. In addition, the OCC noted that the Guidelines cause covered banks to direct significant resources towards developing responsive documentation.

The OCC and the Federal Deposit Insurance Corporation has formally published, in the Federal Register, two regulatory proposals. The proposal would define the term “unsafe or unsound practice” for purposes of section 8 of the Federal Deposit Insurance Act (12 U.S.C. §1818) and revise the supervisory framework for the issuance of matters requiring attention and other supervisory communications. The second proposal would codify the elimination of reputation risk from their supervisory programs.

See the Regulation Tracker for details.

RegulatoryActivity: BankingOperations CFPB DoddFrankAct EnforcementActions FairCreditReporting Preemption PrudentialRegulation StateBankingLaws