On November 21, the Consumer Financial Protection Bureau (CFPB or Bureau) notified staff that it will restart supervision and require examiners, beginning with the 2026 examination cycle, to open each review by reading to the supervised entity a Humility in Supervisions Pledge. The pledge signals a notable shift in tone and execution that is in line with the CFPB’s Memorandum on Supervision and Enforcement Priorities from April 2025. Specifically, examinations will now have tighter alignment to the CFPB’s statutory authority, narrower and more clearly scoped exams (with a focus on “identified priority markets”), greater transparency and predictability, and an express preference to remediate issues in Supervision rather than escalate to Enforcement. It also formalizes a renewed focus on tangible consumer harm, especially to service members, their families, and veterans, and aims to minimize duplicative oversight where states or other regulators are already active.

What the Pledge Says

According to the pledge, the 2026 supervision cycle will be “fundamentally different” from prior cycles under former CFPB Director Chopra. The Bureau intends to emphasize transparency and discipline in scoping: entities will receive advance notice of exams, requests will be tied to stated priorities and remain within scope, and follow-up requests will be discussed with the entity and tailored to the information already supplied.

Findings and Matters Requiring Attention (MRAs) will be framed around pattern-and-practice violations that result in tangible, identifiable consumer harm, or clear violations of disclosure requirements. The Bureau also commits to reducing the duration of exams relative to historical eight-week timeframes, encouraging examiners to conclude work promptly and under budget, and providing timely responses and follow-up on open matters such as exams and MRAs. Finally, the pledge underscores a collaborative approach, inviting self-reporting and seeking to resolve issues within Supervision where feasible rather than through Enforcement. If an institution’s experience diverges from these principles, the pledge directs entities to contact the Office of Supervision Examinations and the Bureau’s Chief Legal Officer.

Funding and Staffing Concerns

It remains unclear how the CFPB will execute this more transparent and resource-intensive supervision model at scale — or at all — given current funding and staffing uncertainty at the Bureau. Furthermore, Acting CFPB Director Russell Vought publicly stated in October that efforts were underway to close down the Bureau by early 2026.

As discussed here, the U.S. Department of Justice (DOJ) notified federal courts that the CFPB may exhaust available funds in early 2026, attaching a November 7 Office of Legal Counsel opinion concluding that the Bureau cannot lawfully draw transfers from the Federal Reserve Board (Fed) while the Fed operates at a loss. The CFPB has told the court it anticipates having sufficient funds to continue operations through at least December 31, 2025, but absent congressional action could face a funding lapse thereafter, which would trigger Antideficiency Act constraints that typically pause most supervision and enforcement activity. Against this backdrop, the CFPB announced it is preparing to transfer its remaining enforcement lawsuits and other active litigation to the DOJ. Thus, it is uncertain how the Bureau will resource and sustain the pledge’s commitments to shorter timelines, tighter scoping, and more timely follow‑up in the 2026 exam cycle.