CFPB Policy Statements

Key dates

2026-08-14

The CFPB announced and implemented the cessation of discretionary publication of complaint narratives and associated visualizations in the Consumer Complaint Database; previously published narratives remain subject to proactive FOIA Reading Room disclosure.

Suggested considerations

• Compliance teams may wish to continue treating CFPB complaints as supervisory and potential enforcement inputs, notwithstanding the removal of narratives from the public database.
• Firms should consider maintaining controls that support complete, accurate, and timely responses to CFPB complaints, including documented investigation, escalation, remediation, and quality-assurance procedures.
• Complaint-management owners may wish to monitor whether the removal of public narratives affects internal trend analysis and should preserve their own historical complaint records and supporting evidence.
• Legal and regulatory affairs teams should consider reviewing previously published complaint narratives concerning the firm in the CFPB FOIA Reading Room and assessing whether existing disclosure, litigation, reputation, and remediation processes remain appropriate.
• Firms should consider retaining evidence supporting complaint responses because complaint information may continue to be shared with prudential regulators, the FTC, and federal or state agencies, and may remain accessible through FOIA.
• Management may wish to avoid interpreting the change as a basis for reducing complaint-governance staffing, monitoring, root-cause analysis, or board and senior-management reporting.

What changed

The CFPB will no longer publish consumer-submitted complaint narratives or related data visualizations in the Consumer Complaint Database. The Bureau characterizes publication of these materials as discretionary rather than statutorily required and states that the materials are unverified, potentially misleading, and not necessarily evidence of legal violations.

Key dates

2023-10-12

CFPB and DOJ issued the joint statement concerning fair lending and credit opportunities for noncitizen borrowers; it was published in the Federal Register on October 18, 2023.

2026-01-12

CFPB and DOJ withdrew the October 2023 joint statement. The withdrawal was published at 91 FR 1138 and became effective on this date.

Suggested considerations

• Compliance teams may wish to identify underwriting, eligibility, pricing, servicing, and adverse-action processes that reference immigration, citizenship, visa, residency, or work-authorization status.
• Firms should consider documenting the legitimate credit, repayment-risk, creditor-rights, remedies, or legal-compliance rationale for collecting or using immigration-related information, rather than treating the withdrawal as an unrestricted authorization to use the information for any purpose.
• Firms may wish to reassess policies adopted in response to the 2023 joint statement, while preserving controls designed to prevent intentional discrimination or unjustified disparate treatment based on race, color, religion, national origin, sex, marital status, or age.
• Compliance teams may wish to test whether immigration-related variables or proxies produce inconsistent eligibility, pricing, or servicing outcomes across protected groups and whether decisioning documentation supports the stated legitimate purpose.
• Firms should consider retaining existing fair-lending governance, adverse-action notice, data-quality, model-risk, and complaint-monitoring controls because the withdrawal does not amend ECOA or Regulation B or eliminate consumer rights.
• California creditors and other firms operating under state or local fair-lending laws may wish to separately assess obligations that are not displaced by the federal withdrawal, including potentially broader state civil-rights protections.

What changed

The nonbinding October 2023 joint statement is withdrawn effective January 12, 2026; no new statutory or regulatory obligation, safe harbor, or mandatory underwriting standard is created. The agencies state that creditors may consider immigration or citizenship status, including when assessing creditworthiness, financial risk, creditor rights and remedies regarding repayment, or compliance with other laws.

Key dates

2025-11-21

CFPB announced the Humility in Supervision Pledge and stated that examiners would read it to supervised entities at the beginning of examinations.

2026-01-01

The pledge applies to the CFPB’s 2026 examination cycle, including the announced focus on priority markets, tangible and identifiable consumer harm, and narrower examination scopes.

Suggested considerations

• Compliance teams may wish to map their 2026 CFPB examination readiness materials to clearly identified products, statutory and regulatory requirements, and documented consumer-harm risks, with particular attention to servicemembers, veterans, and their families.
• Firms should consider maintaining a concise examination scoping pack that identifies relevant business lines, applicable federal consumer financial laws, prior findings, consumer-impact metrics, and information that can be produced without unnecessary overcollection.
• Supervised entities may wish to designate personnel to validate the scope and priority areas when advance examination notice is received and to document any requests that appear unrelated to the stated scope.
• Firms should consider preserving written records of discussions concerning supplemental information requests, scope changes, Matters Requiring Attention, and any proposed self-reporting or supervisory remediation.
• Compliance teams may wish to continue preparing for enforcement-quality examinations because the pledge does not limit the CFPB’s statutory authority or eliminate potential liability for violations, consumer harm, disclosure failures, or unfair, deceptive, or abusive acts or practices.
• Entities experiencing examination activity inconsistent with the pledge may consider escalating the matter through CFPB supervisory channels, while avoiding reliance on the pledge as a defense against substantive compliance deficiencies.

What changed

The CFPB stated that 2026 examinations will focus on pressing consumer threats, particularly issues affecting service members, their families, and veterans, and matters within the Bureau’s statutory authority. The Bureau will seek to avoid duplicative supervision where states or other regulators are already performing substantially the same work. Supervised entities are expected to receive advance notice of scheduled examinations, clearer expectations, and requests limited to the defined scope and identified priorities.

Key dates

2024-05-31

The CFPB published Use of Digital User Accounts to Access Buy Now, Pay Later Loans at 89 Fed. Reg. 47,068, treating covered BNPL lenders as card issuers under Regulation Z.

2025-05-06

The CFPB announced that it would not prioritize enforcement actions based on the BNPL interpretive rule and was contemplating rescission.

2025-05-12

The CFPB subsequently withdrew the 2024 BNPL interpretive rule as part of its withdrawal of guidance documents.

Suggested considerations

• Compliance teams may wish to document the distinction between the CFPB's enforcement-priority statement and a formal repeal, noting that the announcement itself did not provide a safe harbor from the Truth in Lending Act, Regulation Z, UDAAP, Fair Credit Reporting Act, or applicable state law.
• BNPL providers should consider preserving existing Regulation Z implementation records, including disclosures, account statements, dispute and error-resolution procedures, refund processes, complaint files, and change-management documentation, because the CFPB's announcement did not authorize retrospective noncompliance and future policy could change.
• Firms may wish to verify the current status of the 2024 interpretive rule and monitor CFPB Federal Register notices, supervisory publications, litigation developments, and any replacement rule or guidance.
• Product and legal teams should consider reassessing whether each BNPL product is subject to Regulation Z based on its structure and applicable statutory provisions, rather than relying solely on the withdrawn interpretive rule.
• Compliance teams may wish to continue testing disclosures, payment schedules, fees, refund handling, billing-error response, complaint management, and marketing for compliance with remaining federal and state requirements.
• Multi-state providers should consider separately reviewing state licensing, rate, fee, disclosure, dispute-resolution, privacy, and unfair-practices requirements; independent commentary specifically identified New York legislation imposing BNPL licensing and supervision requirements, a 16 percent interest cap, fee restrictions, and additional consumer safeguards.
• Firms may wish to maintain contingency plans that allow rapid restoration or modification of credit-card-style Regulation Z controls if federal enforcement priorities or the legal status of BNPL products changes.

What changed

The CFPB stated that enforcement actions based on Use of Digital User Accounts to Access Buy Now, Pay Later Loans, 89 Fed. Reg. 47,068 (May 31, 2024), would not be a priority. The Bureau said it would redirect enforcement and supervision resources toward pressing consumer threats, particularly those involving servicemembers, veterans, taxpayers, and small businesses. The Bureau also said it was contemplating appropriate action to rescind the interpretive rule; subsequent CFPB materials identified the rule as withdrawn on 2025-05-12.

Key dates

2025-02-07

The Fifth Circuit stayed the Section 1071 rule pending appeal in Texas Bankers Association v. CFPB and tolled compliance deadlines only for the case’s plaintiffs and intervenors, subject to further court modification.

2025-04-30

The CFPB published the policy statement announcing that it would not prioritize enforcement or supervision against entities outside the Fifth Circuit stay.

2025-05-12

The CFPB withdrew the policy statement as part of its broader withdrawal of policy statements, interpretive rules, advisory opinions, and other guidance.

2025-06-18

The CFPB issued an interim final rule extending Section 1071 compliance dates for all regulated entities by approximately one year; the earliest revised date for the highest-volume tier was July 1, 2026.

2026-05-01

The CFPB issued a final reconsideration rule revising Regulation B subpart B and extending the revised framework’s general compliance date to January 1, 2028.

Suggested considerations

• Compliance teams may wish to avoid treating the 2025-04-30 announcement as a formal repeal, exemption, or safe harbor, and should document the distinction between enforcement prioritization and continuing statutory or regulatory obligations.
• Covered lenders should consider preserving existing Section 1071 governance, data mapping, recordkeeping, and implementation work where proportionate, while assessing whether the 2026 final reconsideration rule changes the applicable scope, data points, procedures, or implementation timetable.
• Firms should consider identifying whether they are plaintiffs, intervenors, or members of an association covered by the Texas Bankers Association stay, because the original court order did not apply uniformly to all covered institutions.
• Compliance teams may wish to monitor the CFPB’s Section 1071 rulemaking, the status of Texas Bankers Association v. CFPB, and subsequent Federal Register amendments rather than relying on the withdrawn policy statement as current guidance.
• Lenders should consider retaining an audit trail for any decision to pause, scale, or continue implementation, including legal analysis of the applicable rule version, court orders, CFPB amendments, and operational or fair-lending risks.
• Covered institutions may wish to assess whether existing small-business application and demographic-data processes could support future reporting, because the CFPB’s enforcement posture did not eliminate potential litigation, examination, state-law, fair-lending, or reputational exposure.

What changed

The CFPB stated that it would deprioritize enforcement and supervision of the Small Business Lending Rule against entities not covered by the court-ordered stay, citing limited resources and the perceived unfairness of treating similarly situated institutions differently. The statement did not create a formal exemption, alter Regulation B, remove Section 1071 data-collection and reporting obligations, or expand the Fifth Circuit’s stay, which initially tolled compliance dates only for the plaintiffs and intervenors in Texas Bankers Association v. CFPB.

Key dates

2024-07-08

The final rule was published at 89 Fed. Reg. 56028.

2024-09-16

The final rule became effective.

2025-01-14 Deadline

Initial implementation deadline for larger participant CFPB-supervised covered nonbanks under 12 CFR 1092.206(a)(1).

2025-04-11

The CFPB announced its policy of not prioritizing enforcement or supervision actions for failures to meet future registration deadlines under 12 CFR part 1092.

2025-04-14 Deadline

Implementation registration deadline for other CFPB-supervised covered nonbanks under 12 CFR 1092.206(a)(2).

2025-07-14 Deadline

Implementation registration deadline for all other covered nonbanks under 12 CFR 1092.206(a)(3).

Suggested considerations

• Compliance teams may wish to document whether the entity is a covered nonbank and whether any agency or court order meets the covered-order criteria in 12 CFR 1092.201, including the requirement that the order be a final public order identifying the entity and imposing obligations based in whole or in part on specified consumer-law or UDAAP violations.
• Firms should consider preserving an inventory of potentially covered orders, registration data, and supporting legal analyses even if they elect not to file while the CFPB's prioritization policy remains in effect.
• Covered entities may wish to assess whether filing by the applicable date remains preferable for licensing, supervisory, litigation, diligence, or reputational reasons, rather than treating the announcement as a definitive exemption.
• Compliance teams should monitor for a proposed rulemaking, final rule, formal withdrawal, or further CFPB communication that changes the status or scope of 12 CFR part 1092.
• CFPB-supervised registered entities should continue evaluating the separate annual written-statement requirements in 12 CFR 1092.204 and should not assume that the announcement eliminates obligations other than the future registration-deadline enforcement priority described.
• Firms may wish to record the policy statement as an enforcement-risk and resource-allocation development, not as a statutory safe harbor against other CFPB, state, or private-party consequences for underlying consumer-law violations.

What changed

The CFPB stated that it will not prioritize enforcement or supervision actions concerning failures to submit registration information by future deadlines under the Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders, codified at 12 CFR part 1092. The stated policy covers, among other entities, nonbanks subject to the implementation deadlines in 12 CFR 1092.206(a)(2) and 12 CFR 1092.206(a)(3). The CFPB will instead focus enforcement and supervision resources on pressing threats to consumers.

Key dates

2025-03-28

The CFPB announced that it would not prioritize supervision or enforcement involving penalties or fines under the Payment Withdrawal and Payment Disclosure provisions and said it was considering a rulemaking to narrow the rule's scope.

2025-03-30

The Payment Withdrawal and Payment Disclosure provisions of the Payday, Vehicle Title, and Certain High-Cost Installment Loans Regulation became operative after litigation-related delays.

Suggested considerations

• Firms should continue treating 12 C.F.R. §§ 1041.7 and 1041.9 as operative unless and until a legally effective amendment changes them.
• Compliance teams may wish to preserve controls that prevent additional payment-transfer attempts after two consecutive failed transfers for insufficient funds unless a new authorization satisfying the rule is obtained.
• Firms should review pre-withdrawal, post-failure, and other payment-related notices for compliance with the applicable content, timing, and delivery requirements in 12 C.F.R. § 1041.9.
• Lenders may wish to document the CFPB announcement separately from their formal compliance risk assessment, because the announcement describes enforcement priorities rather than a legal exemption or limitation on private, state, or other applicable enforcement exposure.
• Firms should assess state attorney general and state regulator exposure, including the possibility of enforcement under the Consumer Financial Protection Act and applicable state consumer-protection laws.
• Compliance teams may wish to monitor any CFPB notice of proposed rulemaking, Federal Register publication, litigation, and subsequent effective-date activity before changing production controls.
• Covered lenders should retain evidence of payment-attempt logic, consumer authorizations, notices, exceptions, and records required by the rule so that supervisory or state inquiries can be addressed.

What changed

The CFPB stated that it would deprioritize enforcement and supervision actions concerning penalties or fines associated with the rule's Payment Withdrawal and Payment Disclosure provisions. The operative rule continues to restrict a covered lender from attempting additional payment withdrawals after two consecutive failed attempts caused by insufficient funds unless the consumer provides a new authorization, and it requires specified payment-related notices, including notices before certain withdrawals and after two consecutive failed attempts.