Loan impact
From the rule text · verifiedApplies to: Nonbank covered persons that may be subject to CFPB supervisory designation proceedings under 12 CFR part 1091; no loan-level requirements.
- Affected area
- Enforcement
- Effective
- Oct 27, 2025
- Applicability confidence
- Verified: every row above is supported by the source text
Supporting quotes from the rule
- affected areas“The final rule would apply to covered persons as defined in the CFPA, which are generally entities that engage in offering or providing a consumer financial product or service.”
What changed
From the rule text · Sections 1091.115(c), 1091.101, 1091.108, 1091.105(f)| Requirement | Previously | Now |
|---|---|---|
| Decisions and orders treated as confidential supervisory information (public release rescinded)RemovedSection 1091.115(c) | Previously: The Director could publicly release final decisions and orders designating respondents for supervision. | Decisions and orders in supervisory designation proceedings are confidential supervisory information and not publicly released. |
| Recommended determination by a recommending official reinstatedChangedSection 1091.101, 1091.108 | Previously: The 2024 rule removed the role of the Associate Director of SEFL in providing a recommended determination before the Director's final determination. | A recommending official designated by the Director makes a recommended determination to the Director. |
| Initiating official reply to written response retainedClarifiedSection 1091.105(f) | Not stated | Initiating official may file a reply within 21 days of a respondent's written response. |
| Other 2024 changes not retainedRemoved | Not stated | Other 2024 changes (notice elements, withdrawal of notices, time and word limits, methods of service, multiple respondents, issue exhaustion) are not retained. |
What to do
AWACS interpretation · not source languageWhat to review: First confirm whether the lender is a nonbank covered person that could face a CFPB supervisory designation proceeding under 12 CFR part 1091; if so, note that none of the changes are mandatory. The rule, effective October 27, 2025, restores confidential treatment of decisions and orders and reinstates a recommended determination by a recommending official. It keeps the initiating official's optional reply within 21 days of a written response, and it does not keep the other 2024 changes.
QC implications
- No loan-level testing is needed, since the record states there are no loan-level requirements.
- If the lender is a nonbank covered person that could face a supervisory designation proceeding, QC may confirm that compliance knows decisions and orders in these proceedings are treated as confidential supervisory information and are not publicly released.
Source and record
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Source
- Final rule FR Doc. 2025-18622 (official) ↗ (opens in a new tab)
- Archived copy, SHA-256 d91d06d5b4b3…
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