Overview
- The proposal would define “conduct that poses risks to consumers” as behavior that is highly likely to cause significant harm and directly tied to a consumer financial product or service.
- The rule would replace case‑by‑case designation orders with a uniform legal standard to address concerns about inconsistency and unclear precedent.
- The CFPB notes it has supervised fewer than twenty nonbank entities under this authority and expects designations would be even less frequent under the new standard.
- The Bureau states it should not devote supervisory resources to issues that are speculative in likelihood or trivial in impact and seeks broad public input on the definition.
- Comments are due by September 25, 2025, and if finalized the rule would generally take effect 30 days after publication, with the CFPB also requesting data on its $27,000 per‑exam labor cost estimate.