The two sets of requirements were set to become operative on March 30, 2025, after years of litigation delays. The Payment Withdrawal provisions restrict lenders from making repeated attempts to pull payments from borrowers' bank accounts after two consecutive failed attempts. The Payment Disclosure provisions require advance notice to borrowers before initiating withdrawals.
The Bureau framed the shift as a resource-allocation decision. It said enforcement and supervision resources will remain focused on "pressing threats to consumers, particularly servicemen and veterans," and that the step is being taken in the interest of focusing resources on supporting American taxpayers, servicemen, veterans, and small businesses.
The Bureau also said it is "contemplating issuing a notice of proposed rulemaking to narrow the scope of the rule." Any such rulemaking would require public notice and comment under the Administrative Procedure Act and could take months or years to complete.
The announcement carries no binding legal effect on the underlying rule, which remains in force. Lenders are not shielded from private litigation or state enforcement actions. Routine examination findings tied to the Payment Withdrawal and Payment Disclosure provisions are unlikely to result in civil money penalties or formal enforcement proceedings in the near term.
For practitioners advising payday lenders, auto title lenders, and high-cost installment creditors, the announcement leaves open how long the non-enforcement posture will hold and whether state regulators with parallel authority over unfair or deceptive practices in small-dollar lending will move to fill the gap. Institutions with multistate footprints will need to monitor state-level responses.