Helmed by new leadership, including Acting Director Russell Vought and Chief Legal Officer Mark Paoletta, the Consumer Financial Protection Bureau (“CFPB”) announced earlier this month that it will de-prioritize actions that were aimed at enforcing compliance with the Truth in Lending Act and Buy Now, Pay Later laws. Instead, the CFPB will limit its focus to “pressing threats to consumers” – servicemen and veterans, in particular.  The CFPB, however, did not make clear exactly which laws it will seek to enforce on behalf of servicemen and veterans. The agency also filed a draft Federal Register notice seeking to withdraw nearly 70 interpretive rules, policy statements, and other guidance documents, explaining that in “non-binding policy guidance,” the agency had "adopted interpretations that are inconsistent with the statutory text and impose compliance burdens on regulated parties outside of the strictures of notice-and-comment rulemaking."  

These recent actions are on the heels of a series of scale-back efforts by the CFPB taken in April 2025. Those efforts include the dismissal with prejudice of a complaint filed against Reliant Holdings Inc. (also known as Horizon Card Services) and its CEO, Robert Kane. That lawsuit aimed to hold Reliant and Kane accountable for allegedly overcharging fees to consumers who were deceived into signing up for membership cards. The CFPB also abandoned its appeal of an order striking down a portion of the CFPB’s “prepaid rule” that required digital wallets like PayPal to have the same short-form fee disclosures as ordinary prepaid cards. 

The CFPB has not only sought to offload much of its enforcement actions, but also, most of its staff – roughly 90%. Arguing that it needs only 200 staff members to achieve its more narrowed purpose, the agency obtained an order from the D.C. Circuit Court of Appeals allowing it to lay off 1,500 employees. That order was stayed by an injunction issued by Judge Amy Berman Jackson at the request of the National Treasury Employees Union. But Judge Jackson’s injunction, which also functioned to prevent deletion of data and the deactivation of the CFPB’s consumer complaint-response function, is under scrutiny by the D.C. Circuit Court of Appeals.

The April abandonment of actions and quick move to reduce staff are consistent with the CFPB’s overall desire to shift its focus and resources away from supervision and enforcement that can be accomplished by the states, it says. In an internal memo issued by Chief Legal Officer Paoletta, the CFPB explained it would reduce exams, deprioritize oversight of fintech-related activities, limit scrutiny over nonbank entities, shift back to enforcement actions only against the largest banks, and reduce its fair lending investigations to only those with identified victims with “proven” and clear racial discrimination.