S.J.Res.148 disapproves the Bureau of Consumer Financial Protection’s rule (90 Fed. Reg. 20084, May 12, 2025) that withdrew Bulletin 2022–01 (87 Fed.
Reg. 3025, Jan. 20, 2022). The joint resolution, using chapter 8 of title 5 U.S.C. (the Congressional Review Act), declares the withdrawal rule to have "no force or effect."
For regulated entities—credit reporting agencies, debt collectors, health care providers, insurers, and lenders—this resolution, if enacted, restores the regulatory posture that existed before the CFPB’s 2025 withdrawal. Practically, it preserves the Bureau’s earlier guidance on how medical debt collection and consumer reporting interact with the No Surprises Act and triggers compliance questions for entities that adjusted practices after the withdrawal.
At a Glance
What It Does
The resolution disapproves the CFPB’s 2025 rule that withdrew Bulletin 2022–01 and states that the withdrawal "shall have no force or effect." It is framed as a disapproval under chapter 8 of title 5, the Congressional Review Act, which is the statutory vehicle for nullifying agency rules.
Who It Affects
Directly affected parties include consumer reporting agencies, medical debt collectors, hospitals and other health-care providers, insurers and third‑party billing vendors, and financial institutions that consider medical debt in credit decisions. Consumers with medical billing disputes and state regulators overseeing consumer protections will also feel the impact.
Why It Matters
The resolution would reverse an agency action that changed CFPB guidance on medical-debt reporting, potentially reinstating the regulatory expectations that firms faced in 2022. It reshapes compliance obligations, reopens questions about reporting practices implemented after the withdrawal, and invokes CRA consequences around agencies reissuing similar rules.
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What This Bill Actually Does
S.J.Res.148 is a single-purpose Congressional Review Act resolution aimed at one administrative action: the CFPB’s May 12, 2025 Federal Register entry that withdrew Bulletin 2022–01, which concerned medical-debt collection and consumer reporting in connection with the No Surprises Act. The joint resolution identifies the 2025 Federal Register citation and directs that Congress disapproves that specific agency rule, stating the withdrawal shall have no legal effect.
Under the mechanism spelled out in the resolution, the practical consequence is the nullification of the CFPB’s withdrawal action — leaving in place the state of agency guidance that existed immediately before the 2025 withdrawal. The bill does not amend statutes or create new enforcement tools; it operates by cancelling an administrative rule and thereby restoring the prior administrative posture with respect to the Bulletin.The resolution’s effect touches primarily on administrative law mechanics rather than substantive statutory language: it relies on chapter 8 of title 5 (the Congressional Review Act) as the vehicle for disapproval.
That creates two operational results: first, the specific withdrawal rule is declared void; second, by CRA doctrine, the agency is constrained in reissuing a rule in substantially the same form without further congressional action. Practically, that raises near-term operational issues for entities that changed reporting, billing, or credit‑scoring behavior in response to the CFPB’s 2025 withdrawal.
The Five Things You Need to Know
S.J.Res.148 targets the CFPB Federal Register notice at 90 Fed. Reg. 20084 (May 12, 2025), the agency action that withdrew Bulletin 2022–01.
The resolution states explicitly that the withdrawal rule "shall have no force or effect," thereby nullifying that specific administrative action.
The joint resolution invokes chapter 8 of title 5 U.S.C. — the Congressional Review Act — as the statutory basis for disapproval.
By nullifying the withdrawal, the resolution would leave the earlier CFPB Bulletin (87 Fed. Reg. 3025, Jan. 20, 2022) as the operative guidance unless and until a different lawful action changes it.
The CRA framework implicated by the resolution also limits the agency’s ability to promulgate a substantially similar rule in the future without additional congressional action.
Section-by-Section Breakdown
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Formal congressional resolution language
The bill follows standard congressional format: a short title identifying the subject and an enacting clause that declares the Senate and House of Representatives in Congress assembled. This is procedural but necessary: only a properly formatted joint resolution can operate under the Congressional Review Act to disapprove an agency rule.
Disapproval and nullification of the CFPB withdrawal rule
The single operative sentence declares that Congress disapproves the rule submitted by the CFPB relating to the withdrawal of Bulletin 2022–01 (citing both the original bulletin and the withdrawal’s Federal Register citation) and states that the withdrawal rule "shall have no force or effect." This is a direct exercise of CRA authority: it does not create new obligations but annuls the specific administrative action named in the text.
Precise identification of the targeted Federal Register entries
The resolution names the original Bulletin (87 Fed. Reg. 3025, Jan. 20, 2022) and the withdrawal notice (90 Fed. Reg. 20084, May 12, 2025) to make clear which documents are at issue. That precision matters for implementation and litigation: CRA disapprovals apply only to the rule identified, so the resolution’s text limits its reach to that withdrawal notice rather than to broader CFPB guidance or other related rulemaking.
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Explore Finance in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Consumers with medical debt — preserving the CFPB’s earlier guidance may maintain consumer-facing protections and dispute-resolution expectations that the 2025 withdrawal had removed.
- Consumer advocates and legal services organizations — they retain an administrative reference point (the 2022 Bulletin) to support complaints and enforcement referrals.
- State attorneys general and state regulators — reinstating the Bulletin keeps a federal interpretive text available to coordinate investigations and enforcement across jurisdictions.
- Entities that did not change reporting practices after the 2025 withdrawal — they avoid compliance disruption and litigation risk tied to retroactive operational changes.
Who Bears the Cost
- Hospitals, health systems, and medical billing vendors that adjusted collection and reporting practices after the withdrawal — they may need to reverse operational changes, retrain staff, or restore previously withheld reporting processes.
- Credit reporting agencies and lenders that altered scoring or reporting models following the withdrawal — technical and data‑processing costs could arise if they must revert to earlier practices.
- The CFPB — nullifying an agency action via CRA reduces the agency’s regulatory flexibility and could constrain its near-term rulemaking options on the same subject.
- Private debt buyers and collection agencies that relied on the withdrawal to change collection strategies — they may face renewed limits or scrutiny tied to the original Bulletin’s guidance.
Key Issues
The Core Tension
The central dilemma is straightforward: the resolution restores a federal administrative posture that many see as protective of consumers, but doing so by annulling an agency withdrawal under the CRA limits the Bureau’s ability to revise guidance and forces regulated entities to absorb operational disruption — balancing consumer protection against regulatory clarity and agency flexibility.
The resolution performs a narrow administrative act — it voids a specific agency rule — but that narrowness creates broader implementation questions. First, Bulletin 2022–01 was guidance; courts sometimes treat guidance differently than formal rules.
The resolution cancels a formal withdrawal, but it does not itself convert guidance into a statutory right, nor does it create new enforcement mechanisms. Parties disputing consumer reports or collection practices will still confront the underlying statutory text of the No Surprises Act and any discrete regulatory requirements tied to it.
Second, practical frictions are likely. Many institutions changed systems, contracts, vendor relationships, and internal policies after the 2025 withdrawal.
Reversing those changes can be expensive and operationally complex, especially where state law or private contracts were also adjusted. Finally, while CRA disapprovals have an established legal effect (including limits on reissuance in the same form), they are also common targets for litigation over scope, timing, and whether the agency properly characterized its prior actions.
The resolution leaves open questions about how courts, state regulators, and the industry will interpret the Bulletin’s bindingness and how compliance will be monitored in the short run.
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