On April 16, the CFPB’s Chief Legal Officer, Mark Paoletta, issued a memo outlining the CFPB’s 2025 supervision and enforcement priorities, explaining that the CFPB intends to focus resources towards threats to service members and veterans, and to shift resources away from enforcement and supervision that could be done by states. The memo outlined 11 specific priorities for the CFPB’s supervisory and enforcement efforts through 2025.
The memo explained the Bureau plans to reduce supervisory events by 50 percent while focusing remaining supervisory efforts on “conciliation, correction, and remediation of consumer complaints.” The memo also explained that the CFPB plans to focus more on depository institutions over nonbanks, aiming to allocate 70 percent of its supervisory efforts towards bank, thus returning to its stated supervisory proportions that existed in 2012 and reversing a trend of increasing supervision of nonbanks since 2012. The memo also stated that the Bureau will prioritize addressing actual fraud against consumers resulting in material and measurable damage, focusing in particular on mortgage fraud, FCRA and Regulation V data furnishing violations, FDCPA and Regulation F violations, and fraudulent overcharges and fees.
The memo also stated the CFPB will exercise supervisory authority only in areas that fall clearly under its statutory authority and will not pursue supervision of entities under novel legal theories. Furthermore, the memo stated the Bureau will not engage in unconstitutional racial classification or discrimination in enforcing fair lending laws, focusing only on cases where intentional racial discrimination with identified victims can be proved.
The memo explained that, where it brings enforcement action, the CFPB intends to focus on redressing tangible harm suffered by consumers by returning money directly to them, instead of seeking penalties on companies. In particular, the memo emphasized the Bureau plans to focus on providing redress to service members and veterans. The memo also stated that the Bureau plans to “respect Federalism” by deprioritizing participation in multi-state exams where not required by statute and minimizing duplicative supervision and enforcement where States have substantial regulatory authority. Additionally, the memo stated that the CFPB will respect other federal agencies’ regulatory scopes by eliminating duplicative supervision and coordinating examinations with other federal regulators.
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