The Consumer Financial Protection Bureau (Bureau) recently announced that it is deprioritizing certain enforcement and supervision actions. The Bureau explained that it will instead focus its limited resources on what it views as “pressing threats” to consumers, particularly servicemen and veterans.
On April 30, 2025, the Bureau announced that it will not prioritize enforcement or supervision actions concerning Small Business Lending under the Equal Credit Opportunity Act (Regulation B), with regard to entities that are currently outside the stay imposed under Texas Bankers Association v. CFPB, No. 24-40705 (CA5). Section 1071 of Regulation B requires financial institutions to collect and report certain loan application data from qualifying small businesses. In addition to its constrained resources, the Bureau noted that it would be unfair to enforce Section 1071 “against entities not protected by the court’s stay but similarly situated to parties that are protected by the stay.”
On May 6, 2025, the Bureau announced it will not prioritize enforcement actions against Buy Now, Pay Later lenders, taken on the basis of the Truth in Lending (Regulation Z). Pursuant to an interpretive rule issued by the Bureau on May 31, 2024, Buy Now, Pay Later lenders are required to provide consumers key legal protections and rights that apply to conventional credit cards. The Bureau indicated that it is also now contemplating rescinding the Buy Now, Pay Later interpretive rule.
This reflects an ongoing trend of the Bureau deprioritizing certain enforcement and supervision actions. The Bureau previously announced, on April 11, 2025, that it would not prioritize enforcement and supervision actions concerning the Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders, with regard to entities that do not satisfy future deadlines under the regulation to submit registration information. Similarly, on March 28, 2025, the Bureau announced that it was deprioritizing enforcement and supervision actions concerning the Payday, Vehicle Title, and Certain High-Cost Installment Loans Regulation, with regard to any penalties or fines associated with the payment withdrawal and disclosure provisions.
According to an internal memorandum from April 2025, the Bureau plans to shift its focus back to depository institutions and actual fraud against consumers. It also identified the subject areas that it would prioritize moving forward: mortgages, FCRA/Reg V data furnishing violations, FDCPA/Reg F relating to consumer contracts/debt, and fraudulent overcharges and fees.
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