Consumer Financial Protection Bureau (CFPB)

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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.

According to a recent report by WebRecon, court filings under the Fair Credit Reporting Act (FCRA), Fair Debt Collection Practices Act (FDCPA), and Telephone Consumer Protection Act (TCPA), as well as complaints filed with the Consumer Financial Protection Bureau (CFPB) were all up compared to January 2025. Compared to December 2025, however, the results are mixed. 

In this episode of The Consumer Finance Podcast, host Chris Willis examines signs that the CFPB is reactivating its supervisory and enforcement functions after a period of relative inactivity. The discussion notes reports that the CFPB plans to restart supervisory exams — likely remote, less burdensome, and focused on large banks — and raises questions about whether those exams will address debanking, despite the CFPB’s limited jurisdiction over nonconsumer banking relationships. The conversation also underscores that some previously dormant enforcement investigations are being revived, indicating a return to a more active CFPB.

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.

According to a recent report by WebRecon, court filings under the Fair Credit Reporting Act (FCRA), Fair Debt Collection Practices Act (FDCPA), and Telephone Consumer Protection Act (TCPA), as well as complaints filed with the Consumer Financial Protection Bureau (CFPB) all increased in 2025 compared to 2024. December 2025 filings also rose in every category except TCPA, which declined by only two cases.

In this episode of Moving the Metal, hosts Brooke Conkle and Chris Capurso are joined by Troutman colleagues Chris Carlson and Nam Kang from the firm’s RISE Practice Group to unpack what “Trump 2.0” really means for dealers and auto finance companies. With the Consumer Financial Protection Bureau (CFPB) and other federal regulators pulling back, the group explains how state attorneys general (AGs) and state financial regulators are rapidly filling the void — often led by former CFPB staff now embedded in state offices — and why that creates a complex patchwork of unfair or deceptive acts or practices standards and enforcement approaches across 50 states. They discuss hot-button themes like affordability, junk fees, mini-CFPBs, and the growing role of state working groups, as well as how state AGs are leveraging prior CFPB theories, the California CARS rule, and copy‑and‑paste complaints.

On January 12, the Consumer Financial Protection Bureau and U.S. Department of Justice formally withdrew their October 2023 joint statement on creditors’ consideration of immigration status under the Equal Credit Opportunity Act (ECOA). As we previewed in our December 23, 2025 blog post (available here), the agencies state that the CFPB’s prior statement may have created the misimpression that ECOA or Regulation B impose additional limits on the consideration of immigration or citizenship status beyond the existing regulatory text. The agencies also state that additional guidance on this topic goes beyond Regulation B, so it is unnecessary and appropriate for rescission.

On January 9, the defendants in National Treasury Employees Union (NTEU) v. Vought filed a notice and exhibit in the U.S. District Court for the District of Columbia confirming that the Acting Director of the Consumer Financial Protection Bureau (CFPB or Bureau) has now requested funding from the Federal Reserve Board (Federal Reserve), as required by Judge Amy Berman Jackson’s December 30, 2025 order.

On January 6, the Federal Communication Commission’s (FCC) Consumer and Governmental Affairs Bureau issued an order further extending the effective date of the Telephone Consumer Protection Act (TCPA) “revoke-all” requirement in 47 C.F.R. § 64.1200(a)(10) to January 31, 2027. That provision would require callers to treat a revocation of consent made in response to one type of informational call or text message as applying to all future calls and text messages from that caller on unrelated matters. The Bureau found good cause to continue the waiver while the FCC reviews comments filed in response to its 2025 Further Notice of Proposed Rulemaking, which specifically asks whether the revoke-all rule should be modified or replaced to give consumers more tailored control over unwanted calls. The FCC also noted that requiring companies to implement costly, enterprise-wide changes now could result in unnecessary compliance expenditures if the rule is later revised.