CFPB Proposes Rollback of "Larger Participant" Rules Covering Consumer Debt Collection, International Money Transfer, Automobile Financing, and Consumer Reporting Industries

On August 8, 2025, the Consumer Financial Protection Bureau (CFPB) published four advanced notices of proposed rulemaking (ANPRs) that, if finalized as proposed, would narrow the scope of the CFPB's supervisory authority over four industries: consumer debt collection, international money transfer, automobile financing, and consumer reporting.¹
Comments on the proposed rulemaking are due by September 22, 2025.

Under the Consumer Financial Protection Act, the CFPB has supervisory authority over "larger participant[s] of a market for other consumer financial products or services," as defined by CFPB rules.² The CFPB has since finalized six rules defining larger participants of markets, thereby bringing those participants within the rules’ scope under its supervision.³

Key Thresholds Under Review:

• Consumer Debt Collection: The current threshold for "larger participant" status is $10 million in annual receipts from consumer debt collection activities.⁴ The ANPR does not set out a new threshold, but contemplates the effects of adjusting the threshold to $25 million, $50 million, or $100 million, and invites comments on what an appropriate threshold should be. It also notes that the current $10 million threshold is inconsistent with the Small Business Administration's (SBA's) threshold for classification of a debt collection agency as a small business concern, which is currently $19.5 million.

• International Money Transfer: The current threshold for "larger participant" status is at least one million aggregate annual international money transfers.⁵ The ANPR notes the relative concentration of nonbank international money transferors: approximately 77 percent of estimated remittance transfers are provided by eight non-depository financial institutions. It does not set out a new threshold but considers adjustments to 10 million, 30 million, or 50 million international money transfers per year. It also invites comments on whether annual aggregate money transfers are an appropriate criterion for determining which entities are larger participants.

• Automobile Financing: The current threshold for "larger participant" is at least 10,000 aggregate annual originations.⁶ The ANPR notes that the cost of regulation at this threshold may exceed the benefits, and considers three potential new thresholds of 300,000, 550,000, or 1,050,000 aggregate annual originations.

• Consumer Reporting: The current threshold for "larger participant" status is at least $7 million in annual receipts resulting from relevant consumer reporting activities.⁷ Similar to the ANPR discussion of the consumer debt collection industry, the Consumer Reporting ANPR notes that the current $7 million larger participant threshold is inconsistent with the SBA's threshold for classification of a credit bureau as a small business concern, which is currently $41 million. The ANPR also observes that the CFPB has historically focused its examination efforts on entities in the consumer reporting space with annual receipts exceeding $50 million.

Steptoe will continue to monitor and update on the progress of this rulemaking, which reflects the CFPB’s ongoing recalibration of its oversight priorities. This ANPR offers an important opportunity for stakeholders in affected industries to provide input on this rulemaking process to CFPB decisionmakers. If you are interested in submitting a comment before the September 22, 2025 deadline, Steptoe's Financial Innovation and Regulation team stands ready to assist you.

1 90 Fed. Reg. 38,418 (Aug. 8, 2025); 90 Fed. Reg. 38,412 (Aug. 8, 2025); 90 Fed. Reg. 38,415 (Aug. 8, 2025); 90 Fed. Reg. 38,409 (Aug. 8, 2025).

² 12 U.S.C. § 5514(a)(1)(B).

³ Those industries are: consumer reporting, 77 Fed. Reg. 42874 (July 20, 2012); consumer debt collection, 77 Fed. Reg. 65775 (Oct. 31, 2012); student loan servicing, 78 Fed. Reg. 73383 (Dec. 6, 2013); international money transfers, 79 Fed. Reg. 56631 (Sept. 23, 2014); automobile financing, 80 Fed. Reg. 37496 (June 30, 2015); and digital consumer payment applications, 89 Fed. Reg. 99582 (Dec. 10, 2024).

⁴ 12 C.F.R. § 1090.105(b).

⁵ 12 C.F.R. § 1090. 107(b).

⁶ 12 C.F.R. § 1090.108(b).

⁷ 12 C.F.R. § 1090.104(b).