On March 13, the Consumer Financial Protection Bureau (CFPB or Bureau) released its draft Strategic Plan for FY 2026–2030 and accepted public comment through April 17. The plan, required under the Government Performance and Results Act, sets the Bureau’s mission and priorities for the next four years and explicitly aligns the CFPB’s regulatory strategy with President Trump’s pro‑growth, deregulatory agenda.
On April 17, the Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Federal Reserve), and Federal Deposit Insurance Corporation (FDIC) (collectively, the federal agencies) issued revised interagency guidance on model risk management. The guidance updates and consolidates supervisory expectations for how banks manage the growing use of models across their businesses and effectively manage those risks, while rescinding prior guidance issued by each agency. The updated guidance is principles-based and risk-based, rather than prescriptive, and the federal banking agencies emphasize that model risk management should be tailored to a bank’s model risk profile, as well as the size and complexity of its operations. The agencies further state that non-compliance with the guidance itself will not, standing alone, result in supervisory criticism. That said, weak model risk management can still lead to findings of unsafe or unsound practices or violations of law.
Delaware is positioning itself at the center of digital asset and stablecoin innovation with a coordinated package of legislation aimed at modernizing its banking code and creating a comprehensive framework for payment stablecoins. Senate Bill 16, the “Delaware Banking Modernization Act of 2026,” (SB 16) and Senate Bill 19, the “Delaware Payment Stablecoin Act,” (SB 19) were introduced on March 23, 2026, and are currently moving through the General Assembly. If enacted, both measures would take effect immediately, with implementation required by the earlier of one year after enactment or the issuance of final regulations by the State Bank Commissioner.
As reported by Law360, the U.S. Department of Justice (DOJ) has decided to move forward with its $68 million settlement with Colony Ridge Development LLC without seeking court approval or ongoing judicial oversight. The settlement at issue (discussed here) resolves DOJ and Texas reverse redlining and predatory lending claims in exchange for extensive operational reforms and $48 million in infrastructure improvements plus $20 million in law enforcement and public-safety spending, but no civil money penalties or direct monetary relief to borrowers.
On April 7, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) issued a final rule to remove “reputation risk” from their supervisory and examination frameworks and sharply limit their ability to influence banks’ customer relationships based on political or ideological grounds. This final rule is a central implementation step for President Trump’s debanking initiative under Executive Order 14331, “Guaranteeing Fair Banking for All Americans,” which aims to address concerns about financial institutions improperly restricting access to banking services based on customers’ political, religious, or ideological beliefs.
In this special joint episode of The Consumer Finance Podcast and Payments Pros, guest host Taylor Gess joins Chris Willis and Lori Sommerfield to unpack fair lending risks in point-of-sale finance. They explain how traditional fair lending concepts under the Equal Credit Opportunity Act and Fair Housing Act play out when merchants interact directly with consumers, highlighting risks around discouraging credit applications, discretionary offers, differential assistance, and steering between prime and subprime products. The conversation explores practical risk mitigation tools, such as standardized sales scripts and consumer disclosures, merchant training, and attorney-directed mystery shopping, along with lessons drawn from unfair or deceptive acts or practices enforcement in point-of-sale settings.
The Federal Trade Commission (FTC) has taken a highly visible step into the national debate over “debanking” by sending warning letters to several large payment networks and financial services providers, reminding them that deplatforming or denying customers access to financial products or services due to political or religious beliefs could violate their existing obligations under Section 5 of the FTC Act. The FTC’s letters signal a sharpened enforcement focus on how financial services firms manage account closures, suspensions, and access to services, particularly when political or religious views are implicated.
In this episode of The Consumer Finance Podcast, Chris Willis and Lori Sommerfield unpack the rapid reshaping of the fair lending and UDAAP regulatory enforcement landscape as part of the Year in Review and Look Ahead series. They cover the federal government’s efforts to roll back use of the disparate impact theory, reduce redlining and other enforcement actions, and implement the new debanking initiative, along with the CFPB’s evolving expectations concerning ECOA and Section 1071, and growing state-level oversight as state attorneys general, state regulators, and new state AI/disparate impact regimes fill the federal gap. With long statutes of limitations and 2026 rulemakings ahead, they underscore why financial institutions cannot relax fair lending and UDAAP compliance, even amid apparent federal retreat.
On January 27, the Government Accountability Office (GAO) released a report, Consumer Financial Protection Bureau: Status of Reorganization Efforts (GAO‑26‑108448), that offers a detailed snapshot of the Consumer Financial Protection Bureau’s (CFPB or Bureau) ongoing downsizing and restructuring. This is the first of two GAO reports that focus on the CFPB’s reorganization and its ability to fulfill its statutory functions going forward.
In December 2023, we blogged about lawsuits filed by the Consumer Financial Protection Bureau (CFPB or Bureau), the U.S. Department of Justice (DOJ), and later the State of Texas against Colony Ridge and related entities. The complaints alleged that Colony Ridge targeted Hispanic borrowers with deceptive Spanish‑language marketing, sold largely undeveloped and flood‑prone land, and engaged in predatory financing by steering borrowers into high‑rate, seller‑financed mortgage loans with extremely high foreclosure rates.