The Office of Information and Regulatory Affairs, within the White House Office of Management and Budget, has released the Fall 2025 Unified Agenda of Regulatory and Deregulatory Actions, also called the URA. Published twice a year, the URA outlines federal agencies’ anticipated regulatory and deregulatory activities. While the Fall agenda is typically released by the end of the calendar year or in early January, this edition was delayed, and many of the projected actions may no longer be current.
The Consumer Financial Protection Bureau’s agenda is current as of Jan. 13, 2026, and identifies anticipated regulatory actions from January 2026 through November 2026. Several new items have been added, including proposed rulemakings addressing procedures for guidance documents, periodic review of bureau regulations, and contingency calculations for determining the average prime offer rate. The agenda also includes three new pre-rule actions focused on unfair, deceptive, or abusive acts and practices under Sections 1031 and 1036 of the Dodd-Frank Act, ability-to-repay and qualified mortgage requirements, and prepaid accounts under Regulations E and Z.
According to the agenda, the CFPB expects to issue proposed rules on Section 1033 personal financial data rights, payday lending, and APOR contingency calculations by the end of July this year. Four proposed “larger participant” rules are expected by the end of September 2026.
Several rulemakings have also advanced to the final rule stage. Final rules addressing Regulation X servicing amendments and remittance transfers under the Electronic Fund Transfer Act are expected by the end of summer 2026. The final rules relating to the Section 1071 reconsideration, Equal Credit Opportunity Act Regulation B disparate impact standards, and implementation of the Financial Data Transparency Act, have already been issued.
In the Bank Secrecy Act/anti-money laundering space, FinCEN now expects to issue its long-awaited proposed revisions to the customer due diligence rule next spring. Notably, the agenda does not provide target dates for finalizing the Bank Secrecy Act program rule changes proposed in April 2026, and the Federal Reserve — which did not join that notice of proposed rulemaking — did not include any BSA program amendments in its own agenda.
FinCEN’s agenda includes seven proposed rules and three final rules, including GENIUS Act implementation (in coordination with the federal banking agencies and Treasury), the revised customer due diligence rule, a notice of proposed rulemaking expected in September to narrow customer identification program requirements for investment advisers, proposed Foreign Bank Account Report reporting changes intended to reduce burden for certain filers by March 2027, and finalization of its whistleblower rule. FinCEN also plans to finalize two Section 311 rulemakings and the March 2025 interim final rule on beneficial ownership reporting.
ABA is expected to publish a staff analysis on the Fall 2025 URA in the coming days. Access the regulatory agenda here.
