While updates to Regulation X are needed, many of the bureau’s proposed changes will create limitations or additional challenges for mortgage servicers, according to industry experts.

The regulators clarified that the final document is intended to be limited to “real estate-related financial transactions that are secured by a single 1-to-4 family residential property.”

The proposed rule fails to provide a bright-line test for lenders and employers, an attorney with the Dorsey & Whitney law firm said.

The proposal includes some aspects supported by both servicers and consumer advocates and some provisions that could see pushback from servicers.

CFPB rules are likely to face challenges and the bureau may shift to using enforcement actions as a form of policymaking.

Only four proposed rules are on track to come from the CFPB by May 2025, according to the latest regulatory agenda.

The CFPB set new implementation dates for its small business lending data reporting rule and the payday lending rule. However, the new deadlines could still face court challenges.

A district court’s order focused on RESPA violations following a loan default.

The ABA is expecting the CFPB to finalize two rules — one on overdraft fees and another on nonsufficient funds fees — within the next few months.

Pete Mills, a senior vice president at the Mortgage Bankers Association, said the registry is an “unnecessary and redundant move.” The final rule requires nonbanks to report to the CFPB any government or court orders penalizing them for violations of consumer protection laws.