AWACSMortgage compliance intelligence from Flightline

CFPB · Interpretive rule FR Doc. 2025-19671 · Published

FCRA Preemption of State Laws: Interpretive Rule Replacing Withdrawn 2022 Rule

The CFPB confirms the withdrawal of its July 2022 interpretive rule on FCRA preemption and states that the FCRA generally preempts State laws touching broad areas of credit reporting. The rule is guidance with no binding legal effect and imposes no new obligations.

Review recommendedEffective Oct 28, 2025All checks passedRead the rule ↗ (opens in a new tab)

Loan impact

From the rule text · verified

Applies to: Consumer reporting agencies, credit report users and furnishers subject to the FCRA; the rule is non-binding guidance on State law preemption.

Affected area
Report
Effective
Oct 28, 2025
Applicability confidence
Verified: every row above is supported by the source text
Supporting quotes from the rule
  • affected areas“The Bureau is also clarifying that the FCRA 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.”

What changed

From the rule text
RequirementPreviouslyNow
Clarification of broad FCRA preemption of State credit reporting lawsClarifiedNot statedFCRA generally preempts State laws touching broad areas of credit reporting
Withdrawal of 2022 FCRA preemption interpretive rule confirmedRemovedNot stated2022 interpretive rule withdrawal confirmed

What to do

AWACS interpretation · not source language

What to review: No change is mandatory, so compliance may review the CFPB's clarification that the FCRA generally preempts State laws touching broad areas of credit reporting and its confirmed withdrawal of the 2022 interpretive rule, which is non-binding guidance applicable October 28, 2025.

QC implications

  • No mandatory change here, so QC has no new requirement to test against this rule.
  • QC may check that credit reporting practices are not relying on the withdrawn 2022 interpretive rule on FCRA preemption.

Source and record

Version 1 · archived

Checks passed

  • Schema valid
  • Effective quotes verbatim
  • Document ID appears in the source
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  • Mandatory entries have requirement language
  • Published on present
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  • Source link resolves
  • Loan impact quotes verbatim
  • Loan impact vocabulary
  • Changes quoted
  • Impact type consistent
  • Every required change is backed by obligation language
  • Only new or tightened changes are marked required
  • Loan impact covers every required change
  • Quotes are complete sentences
  • Unflagged must
  • Diff complete
  • Mandatory date resolved
  • Audience verbatim
  • Scope residential
  • Out of scope
  • Published in window
  • Interpretation schema valid
  • Interpretation separate