CFPB releases 2025 supervision and exam priorities

In its newly released 2025 exam and supervision priorities sent to staff, the CFPB says it will focus its enforcement and supervision resources on threats to consumers - in particular veterans, service members and their families. The Bureau outlined 11 priorities.  

While America’s Credit Unions supports many of these priorities, it does have concern with the Bureau’s intended shift away from nonbank financial companies and non-mortgage related concerns.  

“America’s Credit Unions applauds the Consumer Financial Protection Bureau’s recent shift toward efficient, targeted supervision that prioritizes measurable harm, avoids duplicative oversight, and reinforces clarity in enforcement. These changes promise to reduce regulatory burden on responsible institutions while refocusing attention on bad actors,” America’s Credit Unions President/CEO Jim Nussle said. “However, America’s Credit Unions urges a broader approach where non-depository institutions face supervisory attention in alignment with credit unions and other highly regulated financial institutions. Given their significant growth, influence, and operations in similar products and services, the lack of comparable oversight risks gaps in consumer protection.”    

The newly issued supervision and exam priorities are as follows:

1. Supervision shall decrease the overall number of “events” by 50%.
2. The Bureau’s focus will shift back to depository institutions, as opposed to non-depository institutions.
3. The Bureau will focus on actual fraud against consumers, where there are identifiable victims with material and measurable consumer damages. The areas of priorities are:
   
   1. Mortgages (getting the highest priority).
   2. FCRA/Reg V data furnishing violations.
   3. FDCPA/Reg F relating to consumer contracts/debts.
   4. Various fraudulent overcharges, fees, etc.
   5. Inadequate controls to protect consumer information resulting in actual loss to consumers.
4. The Bureau will focus on redressing tangible harm by getting money back directly to consumers.
5. The Bureau will focus on providing redress to service members and their families, and veterans.
6. The Bureau will respect Federalism:
   
   1. The Bureau will deprioritize participation in multi-state exams unless required by statute.
   2. The Bureau will deprioritize supervision where States have and exercise ample regulatory and supervisory authority, unless required by statute.
   3. The Bureau will minimize duplicative enforcement, where State regulators or law enforcement authorities are currently engaged in or have concluded an investigation into the same matter.
7. The Bureau will respect other federal agencies’ regulatory ambit:
   
   1. The Bureau will eliminate duplicative supervision or supervision outside of the Bureau’s authority.
   2. To the extent feasible, the Bureau will coordinate exams’ timing with other/primary federal regulators.
   3. The Bureau will minimize duplicative enforcement, where another federal regulator is currently engaged in or has concluded enforcement.
8. The Bureau will not pursue supervision under novel legal theories, including of the Bureau’s authority.
9. The Bureau will not engage in or facilitate unconstitutional racial classification or discrimination in its enforcement of fair lending law:
   
   1. The Bureau will not engage in redlining or bias assessment supervisions or enforcement based solely on statistical evidence and/or stray remarks.
   2. The Bureau will pursue only matters with proven actual intentional racial discrimination and actual identified victims.
10. The Bureau will deprioritize the following:
    
    1. Loans or other initiatives for “justice involved” individuals.
    2. Medical debt.
    3. Peer-to-peer platforms and lending.
    4. Student loans.
    5. Remittances.
    6. Consumer data.
    7. Digital payments.
11. The Bureau’s primary consumer enforcement tools are its disclosure statutes. The Bureau shall not engage in attempts to create price controls.