SJR125 is a Congressional Review Act joint resolution that disapproves a Bureau of Consumer Financial Protection (CFPB) rule which withdrew the agency’s earlier Regulation F ‘Pay‑to‑Pay Fees’ rule. The resolution states that the CFPB’s withdrawal rule "shall have no force or effect," which would leave the 2022 Regulation F pay‑to‑pay fee rule in place.
Why it matters: nullifying the withdrawal does more than reverse an administrative action — it invokes the CRA’s bar on reissuing a "substantially the same" rule without new statutory authorization. That limitation and the restoration of the 2022 rule would directly affect debt collectors, creditors, payment vendors, and consumers who pay collection-related fees.
At a Glance
What It Does
SJR125 uses chapter 8 of title 5 (the Congressional Review Act) to disapprove the CFPB rule that withdrew the 2022 Regulation F pay‑to‑pay fee rule; the text declares the withdrawal rule invalid and therefore without legal effect. By operation of the CRA, the disapproval also restricts the agency from promulgating a substantially similar rule in the future unless Congress authorizes it.
Who It Affects
Directly affected are the CFPB (as the issuing agency), entities subject to Regulation F — principally debt collectors and creditors who may have charged or planned to charge pay‑to‑pay fees — and consumers who face those fees. Payment processors and compliance vendors that implement collection‑payment workflows would also need to adapt.
Why It Matters
This resolution addresses regulatory permanence and agency flexibility: it aims to preserve a regulatory constraint on charging certain consumer fees while using the CRA’s long‑term prohibition on substantially similar rules to make that preservation durable. Compliance teams, legal counsels, and product managers in consumer‑finance firms need to know whether the withdrawal will be nullified and whether the CFPB can reissue comparable restrictions.
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What This Bill Actually Does
SJR125 contains a single substantive sentence: Congress disapproves the CFPB’s rule withdrawing the earlier Regulation F pay‑to‑pay fee rule and declares that withdrawal void. In practical terms, passage of this joint resolution would undo the CFPB’s May 12, 2025 Federal Register notice that removed the 2022 pay‑to‑pay fee regulation; the 2022 rule would remain in force because the act that eliminated it would be treated as if it never took legal effect.
Beyond nullifying the withdrawal, invoking the Congressional Review Act carries an additional legal consequence: once Congress disapproves a rule under the CRA, the administering agency cannot reissue a rule that is "substantially the same" without new statutory authority. That means the CFPB could not simply re‑adopt the same withdrawal in a different procedural form; it would face a meaningful barrier to reversing Congress’s judgment absent new legislation or a significantly different regulatory approach.For regulated entities, the resolution’s practical implications run to compliance operations and product design.
If the resolution becomes law, firms that had planned to resume charging pay‑to‑pay fees or to change billing workflows to reflect the withdrawal would need to retain or reinstate controls to prevent those fees where the 2022 rule prohibits them. Conversely, consumer advocates and staff administering collections will rely on the continued applicability of the 2022 rule to challenge fee practices that the CFPB previously targeted.The text of SJR125 does not amend Regulation F itself nor spell out enforcement detail; it simply declares the withdrawal rule invalid.
The downstream effects — enforcement priorities, supervisory guidance, and litigated disputes about what counts as a pay‑to‑pay fee — would be handled through existing CFPB supervisory and enforcement channels, or through court challenges over interpretation and scope.
The Five Things You Need to Know
SJR125 is a Congressional Review Act joint resolution that disapproves the CFPB’s May 12, 2025 rule that withdrew the Regulation F pay‑to‑pay fee rule (90 Fed. Reg. 20084).
The 2022 pay‑to‑pay fee rule cited in the resolution appears at 87 Fed. Reg. 39733 (July 5, 2022); disapproval of the withdrawal would leave that 2022 rule operative.
The resolution’s statutory hook is chapter 8 of title 5, United States Code (the CRA), which both voids the targeted rule and bars the issuing agency from later promulgating a substantially similar rule without express congressional authorization.
SJR125’s text is a single, direct disapproval clause: it declares the specified withdrawal rule to have "no force or effect.", The joint resolution was introduced by Senator Angela Alsobrooks on March 17, 2026 and was referred to the Senate Committee on Banking, Housing, and Urban Affairs.
Section-by-Section Breakdown
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Congressional disapproval of CFPB withdrawal rule
The entire operative text consists of Congress declaring that it "disapproves the rule" the CFPB submitted concerning the withdrawal of the Regulation F pay‑to‑pay fee rule and stating that the withdrawal "shall have no force or effect." That language mirrors the statutory remedy in the Congressional Review Act: invalidation of the specified agency action. Practically, the single clause both negates the agency’s withdrawal action and signals Congress’s affirmative choice to keep the earlier regulatory position in place.
Use of chapter 8 of title 5 (CRA) as mechanism
By invoking chapter 8 of title 5, the resolution operates under the CRA framework, which provides a twofold consequence for disapproved rules: the targeted rule loses legal effect, and the agency is prevented from issuing a substantially similar rule without new congressional authorization. That statutory basis is what converts a one‑line disapproval into a long‑lasting constraint on future agency rulemaking behavior.
Specific Federal Register citations and rule history referenced
The resolution cites the CFPB withdrawal notice by Federal Register citation (90 Fed. Reg. 20084, May 12, 2025) and references the original Regulation F pay‑to‑pay fees rule (87 Fed. Reg. 39733, July 5, 2022). Those citations narrow the disapproval to a discrete agency action — the withdrawal notice — rather than to broader regulatory text, which has implications for legal challenges about scope and for agencies attempting to craft compliant successor actions.
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Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Consumers subject to collection fees — Preserving the 2022 Regulation F pay‑to‑pay fee rule would protect consumers from certain collection‑related payment fees that the earlier rule addressed, reducing out‑of‑pocket costs for people making payments to resolve debts.
- Consumer advocacy organizations — Groups that litigate or lobby on behalf of fee restrictions gain a regulatory baseline they can rely on in enforcement referrals and public education.
- State attorneys general and private plaintiffs — Having the 2022 rule remain in effect strengthens administrative and private enforcement claims premised on the existing regulatory standard.
Who Bears the Cost
- Debt collectors and creditors who charge pay‑to‑pay fees — These firms would lose the ability to lawfully impose certain payment fees and must maintain or implement compliance controls to avoid prohibited charges.
- Payment processors and third‑party vendors — Firms that build payment flows for collections will face product and contractual changes to block or prevent fee structures disallowed by the 2022 rule.
- The CFPB — If disapproved, the agency loses regulatory flexibility; it cannot promptly replace the withdrawal with a substantially similar rule and may incur litigation or administrative burdens defending the scope and meaning of the surviving 2022 rule.
Key Issues
The Core Tension
The central dilemma is between preserving a consumer‑protective regulatory constraint (preventing certain pay‑to‑pay fees) and protecting the executive agency’s ability to revise or rescind its rules in light of changing facts or priorities; the CRA resolution locks in a policy choice made by Congress and limits the CFPB’s future regulatory flexibility, which can prevent backsliding but can also freeze agency responses to new evidence or market developments.
The resolution is short but its legal footprint is broad because of the CRA’s secondary effect. One implementation challenge is interpretive: courts and regulated parties may dispute which parts of the 2022 rule survive intact and whether particular fee practices fall within the scope of the preserved text.
The resolution nullifies a withdrawal notice rather than amending substantive regulatory text; that form can generate litigation over whether subsequent CFPB guidance or enforcement steps implicitly accomplish what the withdrawn rule sought to change.
A second tension concerns the CRA’s prohibition on "substantially the same" rules. That phrase is familiar but fact‑specific: agencies may attempt to craft modified rules that achieve similar outcomes while asserting they are not "substantially the same," and regulated parties may challenge those efforts.
The provision therefore substitutes a difficult line‑drawing exercise — judicial and administrative tests of substantial similarity — for the clearer path of direct statutory amendment, producing potential regulatory uncertainty over how durable the preservation of the 2022 rule really is.
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