S.J.Res. 150 – CRA Disapproval of CFPB Digital Marketing ‘Time or Space’ Rule Withdrawal
Current understanding
S.J.Res. 150 is a Congressional Review Act joint resolution to disapprove the CFPB’s rule withdrawing an earlier interpretive rule on the ‘Limited Applicability of Consumer Financial Protection Act’s Time or Space Exception With Respect to Digital Marketing Providers.’ The underlying CFPB position had treated certain digital marketing providers as covered service providers (rather than as excepted ‘time or space’ vendors) under the CFPA, exposing them to consumer-financial-data supervision. The Senate rejected the motion to proceed on the resolution, leaving the CFPB’s withdrawal in effect; digital marketing providers therefore continue to fall outside the narrowed reading of the exception for now. Status: motion to proceed rejected in the Senate.
Evidence log
- 2026-03-26 — A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to the withdrawal of the rule relating to “Bulletin 2022-01: Medical Debt Collection and Consumer Reporting Requirements in Connection with the No Surprises Act”.: cross-connection with sjres148-cfpb-medical-debt-bulletin-withdrawal: Companion CRA resolution in the same series challenging CFPB rule withdrawals affecting consumer data and reporting. (novelty: 3)
- 2026-05-13 — A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to the withdrawal of the rule relating to “Limited Applicability of Consumer Financial Protection Act’s ‘Time or Space’ Exception With Respect to Digital Marketing Providers”.: cross-connection with cfpb-circular-2022-04-data-protection: Both are CRA joint resolutions contesting CFPB withdrawals of 2022-era consumer-data instruments; S.J.Res. 150 targets the digital marketing ‘time or space’ interpretive rule while the Circular 2022-04 resolution targets the data-security UDAAP circular. (novelty: 2)