On April 16, 2025, Mark Paoletta, Chief Legal Officer of the Consumer Financial Protection Bureau (CFPB or the Bureau), issued an internal memorandum to CFPB staff outlining the agency’s supervision and enforcement priorities for the year. The Bureau announced it will concentrate its efforts on addressing concrete consumer harms and urgent threats, with a particular focus on protecting service members, veterans, and their families. At the same time, the CFPB intends to reallocate resources away from enforcement and oversight activities that can be effectively carried out by state authorities. The memo stated that all prior enforcement and supervision documents are “hereby rescinded,” and sets out eleven key points regarding the CFPB’s priorities for 2025, including:
- Reducing supervisory exams, decreasing the overall number of “events” by 50%, to focus on conciliation, correction, and remediation of harms subject to consumer complaints.
- Shifting the Bureau’s focus back to large banks and depository institutions, as opposed to non-depository institutions.
- Focusing on actual fraud against consumers, “where there are identifiable victims with material and measurable consumer damages as opposed to matters based on the Bureau’s perception that consumers made the wrong choices,” with the areas of priorities being mortgages (getting the highest priority), Fair Credit Reporting Act (FCRA)/Reg V data furnishing violations, Fair Debt Collection Practices Act (FDCPA)/Reg F relating to consumer contracts/debts, various fraudulent overcharges, fees, etc., and inadequate controls to protect consumer information resulting in actual loss to consumers.
- Redressing tangible consumer harm by getting money back directly to consumers, rather than imposing penalties.
- Seeking redress for service members, their families, and veterans.
- Respecting federalism by deprioritizing participation in multi-state exams and supervision where States have and exercise ample regulatory and supervisory authority, unless required by statute, and minimizing duplicative enforcement with other State regulators or law enforcement.
- With regard to other federal agencies, the Bureau will seek to eliminate duplicative supervision, minimize duplicative enforcement, and better coordinate exams with other federal regulators.
- Avoiding supervision under novel legal theories with a focus on supervision within the CFPB’s statutory authority.
- Committing to not engaging in or facilitating unconstitutional racial classification or discrimination in the enforcement of fair lending law by pursuing only matters with proven actual intentional racial discrimination and identified victims. “Such matters shall be brought to leadership’s attention and maximum penalties will be sought.”
- Deprioritizing medical debt, peer-to-peer platforms and lending, student loans, remittances, consumer data, digital payments, and loans or other initiatives for “justice-involved” individuals (criminals).
- Highlighting the Bureau’s use of disclosure statutes as its primary consumer enforcement tools and disengaging in attempts to create price controls.
What does this mean for the future of CFPB’s enforcement efforts?
The CFPB’s recent memo signals a continued commitment to enforcement, albeit with a markedly different set of priorities from previous administrations. By rescinding previous documents and reducing supervisory exams by 50%, the CFPB aims to concentrate its efforts on consumer complaints and tangible consumer harms. The shift from broad enforcement to targeting identifiable fraud and actual consumer damages reflects a prioritization of direct consumer benefits and an attempt to streamline resources by reducing duplication of efforts with state and other federal agencies, encouraging other state agencies to increase their oversight.
Furthermore, by deprioritizing areas like medical debt and digital payments, and refocusing on frauds such as mortgage and Fair Credit Report Act violations, the CFPB is narrowing its scope to areas where it sees the most pressing threats and consumer harm. Entities working in the mortgage and lending spaces, as well as other priority areas, should continue to monitor their practices to ensure compliance with applicable laws and avoid consumer harm as we wait to see how these changes manifest.
