The Office of Information and Regulatory Affairs, part of the White House’s Office of Management and Budget, this week released the Fall 2024 Unified Agenda of Regulatory and Deregulatory Actions. This semi-annual report outlines each federal agency’s plans to propose, finalize or rescind regulations. The rules listed in the report are currently under development and may be influenced by the incoming administration.
The Consumer Financial Protection Bureau’s agenda contains several rulemakings in their final stages. Notably, it anticipates releasing multiple final rules this month, including those addressing medical debt reporting under the Fair Credit Reporting Act, nonsufficient fund fees for instantaneously declined transactions and requirements under the Financial Data Transparency Act. It also anticipates releasing final rules on remittance transfers in March 2025, mortgage servicing in July 2025, contract terms and conditions registry for nonbanks in June 2025. The bureau released its final rule on residential Property Assessed Clean Energy financing today.
The proposed rule on Regulation AA related to certain provisions in consumer credit contracts is expected to be released this month as well. The CFPB projects June 2025 to begin prerule activities on a proposal related to customer service practices, and projects October 2025 to begin prerule activities on a proposal related to mortgage closing costs.
In the Bank Secrecy Act space, the Financial Crimes Enforcement Network anticipates it will issue a proposal to revise the customer due diligence rule in April, and propose rules to protect information shared through FinCEN Exchanges and establish a whistleblower award program, respectively. FinCEN also projects it will finalize a new BSA program rule in March, as well as require registered investment advisers to implement a CIP program. Finally, it also plans to impose special measures with respect to certain CVC mixing as a class of transactions.
Notably, in the regulatory agenda, of the primary federal regulators, only the Federal Reserve projects undertaking BSA-related rulemaking at this time. The Fed projects that along with the Office of the Comptroller of the Currency, FDIC and National Credit Union Administration, it will propose additional revisions to their respective BSA program rules, with further action anticipated in June. Previously, the agencies coordinated their approach to program rule revisions, both in substance and in timing. However, as these dates are likely highly preliminary in nature, much could change.
The American Bankers Association is planning to publish a staff analysis on the fall regulatory agency in the coming days.
