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CFPB Shifts Priorities for 2025

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On April 16, 2025, the Consumer Financial Protection Bureau (CFPB) issued an internal memo to staff announcing new priorities for the agency in 2025. The priorities are a dramatic shift for the CFPB from the previous administration. Among the priorities are the following:

  • Decrease the number of exams by 50%.
  • Focus more on depository institutions rather than non-depository institutions.
  • Prioritize compliance testing in the following areas:
    • Mortgages (getting the highest priority)
    • Fair Credit Reporting Act data furnishing violations
    • Fair Debt Collection Practices Act
    • Fraudulent overcharges and fees
    • Inadequate controls to protect consumer information resulting in actual loss to consumers
  • Focus on providing redress to service members and veterans.
  • Deprioritize participation in multi-state exams, unless required by statute.
  • Deprioritize supervision where states exercise sufficient regulatory and supervisory authority, unless required by statute.
  • Minimize duplicative enforcement with state regulators or law enforcement.
  • Coordinate exam timing with other federal regulators.
  • Do not pursue supervision under novel legal theories.
  • Do not engage in unconstitutional racial classification or discrimination in its enforcement of fair lending law.
  • Do not engage in redlining or bias assessment supervisions or enforcement based solely on statistical evidence and/or stray remarks.
  • Pursue only matters with proven actual intentional racial discrimination and identified victims.
  • Deprioritize the following:
    • Loans or other initiatives for criminals
    • Medical debt
    • Peer-to-peer platforms and lending
    • Student loans
    • Remittances
    • Consumer data
    • Digital payments
  • Primary consumer enforcement tools are its disclosure statutes.
  • Do not engage in attempts to create price controls.

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John Zasada Doeren Mayhew
John Zasada
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John Zasada is a Principal in Doeren Mayhew's Financial Institutions Group, where he assists financial institutions in navigating regulatory compliance.

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