On August 8, the CFPB published four advance notices of proposed rulemaking in the Federal Register seeking public comment to reconsider the test for defining larger participants in the consumer reporting, debt collection, international money transfer, and automobile financing markets.

Defining Larger Participants of the Consumer Debt Collection Market

The CFPB issued an advance notice of proposed rulemaking seeking public comment on whether to revise the criteria for defining larger participants in the consumer debt collection market under the Bureau’s Defining Larger Participants of the Consumer Debt Collection Market Rule. Currently, nonbank entities with over $10 million in annual receipts from consumer debt collection activities are classified as larger participants and subject to CFPB supervision. The Bureau is concerned that this threshold may impose disproportionate compliance burdens on smaller businesses and does not reflect industry consolidation or updated Small Business Administration (SBA) size standards for a “small business concern,” which have risen to $19.5 million from $7 million in 2013. The CFPB was requesting feedback on whether the threshold should be changed, how potential changes could impact consumers, market participants, and the Bureau’s supervisory resources, as well as whether new data sources or SBA standards should inform the criteria. The Bureau invited public comments to consider whether to propose changes to the rule.

 Defining Larger Participants of the International Money Transfer Market

The CFPB issued an advance notice of proposed rulemaking seeking public comment as it considers whether to propose amending the test that defines larger participants in the international money transfer market — a standard originally established by the Bureau’s 2014 Defining Larger Participants of the International Money Transfer Market Final Rule. The current threshold defines a larger participant as a nonbank covered person with at least 1 million aggregate annual international money transfers. The CFPB noted it was not aware of a data source where institutions report their total number of international money transfers in a manner fully consistent with the definition. The Bureau also observed that the market for international money transfers is heavily concentrated. For example, if the Bureau raised the threshold from 1 million to 10 million international money transfers per year, it estimates that approximately 15 nonbank covered persons would qualify as larger participants (from the 28 current covered persons) and that these entities would provide an estimated 94 percent of all international money transfers.

Defining Larger Participants of the Automobile Financing Market

The CFPB issued an advance notice of proposed rulemaking seeking public comment on whether to propose a rule amending the test that defines larger participants in the automobile financing market. The Bureau established the Defining Larger Participants of the Automobile Financing Market and Defining Certain Automobile Leasing Activity as a Financial Product or Service Final Rule in 2015. Currently, nonbank entities with at least 10,000 aggregate annual originations are considered larger participants. Based on 2024-2025 industry data, about 63 entities — including specialty finance companies, captives, and buy-here-pay-here finance companies — meet this threshold, accounting for an estimated 17.4 million consumer transactions, or roughly 94 percent of annual originations. The Bureau was considering whether raising the threshold would better focus its supervisory resources on the most active market participants and is seeking public input on the potential impacts of such a change.

Defining Larger Participants of the Consumer Reporting Market

The CFPB issued an advance notice of proposed rulemaking seeking public comment on whether to amend the test that defines larger participants in the consumer reporting market, as established by the agency’s 2012 Defining Larger Participants of the Consumer Reporting Market Final Rule. The Bureau expressed concern that its current supervisory threshold — more than $7 million in annual receipts from relevant consumer reporting activities — may not justify the compliance burdens imposed on many entities now considered larger participants, particularly smaller businesses. The CFPB noted the broad pool of supervised entities could be diverting limited agency resources and considered whether to update the threshold, potentially aligning it with the Small Business Administration’s $41 million size standard, or to use some alternative criteria. The agency will be soliciting comments on the threshold, alternative measures, the use of various data sources, and the potential impacts on consumers, market participants, and regulatory oversight.

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