CBA Urges CFPB To Finalize a Strategic Plan Grounded in Statutory Discipline, Durable Regulation, and Robust Nonbank Supervision

WASHINGTON, D.C. - In a letter sent to the Consumer Financial Protection Bureau (CFPB), the Consumer Bankers Association (CBA) responded to the Bureau's Draft Strategic Plan for Fiscal Years 2026-2030. In the letter, CBA urged the agency to finalize a plan that is firmly grounded in statute-in this case, the Dodd-Frank Wall Street Reform and Consumer Protection Act, focused on tangible consumer harm, and committed to evenhanded oversight across banks and nonbanks.

Commenting on the Bureau's Draft Strategic Plan, which follows the release of a January 2025 CBA white paper outlining necessary and meaningful reforms to the CFPB, CBA President and CEO Lindsey Johnson said in a new statement:

"CBA has long emphasized the importance of the CFPB operating as a credible, durable, and stable regulator, and we are encouraged to see these principles reflected here.

"The Bureau's focus on adhering to its statutory mandate, targeting clear consumer harm, and strengthening coordination with prudential regulators represents a constructive step toward the kind of approach that best serves consumers and markets alike. However, within the Strategic Plan one area, which proposes to shift supervision focus away from nonbanks, is inconsistent with the statute and warrants reconsideration.

"As we convey in our letter, America's leading retail banks and the Bureau serve the same consumers and share the same goal: a financial marketplace that is fair, transparent, competitive, and innovative. CBA looks forward to working with the Bureau as it finalizes this plan and puts these principles into practice in the years ahead."

Why It Matters

CBA's letter supports several key elements of the Bureau's draft strategic plan, including:

• Harm-focused enforcement: Enforcement and supervision should prioritize identifiable victims, measurable harm, and clear legal standards, rather than novel theories or retroactive interpretations.
• Reduced regulatory burden: The CFPB should rigorously assess the costs and benefits of major actions, including effects on access to credit, innovation, and cumulative regulatory burden.
• Meaningful regulatory coordination: The Bureau should improve coordination with prudential regulators in a way that reduces duplication, aligns supervisory conclusions, and reflects a more coherent division of labor.
• Improved complaint data integrity: Complaint data should be reliable, verified, and fit for use in risk-based supervision.

CBA's Core Concern

CBA also explains that the CFPB's stated intention to shift supervisory focus toward depository institutions and away from non-depository institutions cannot be reconciled with the structure and text of the Dodd-Frank Act.

Congress created the CFPB, in part, to close supervisory gaps in the nonbank market and to ensure federal consumer financial law is enforced consistently, regardless of charter type. CBA stressed that nonbank supervision is not peripheral to the Bureau's mission - it is central to it. As the letter states:

"As nonbanks continue to play a larger role in mortgages, payments, and other consumer financial markets, retreating from nonbank supervision would not reduce risk to consumers - it would increase it. A CFPB that steps back from supervising nonbanks is not a more focused regulator. It is a less complete one."

Additional Recommendations

In its letter, CBA also urged the Bureau to:

• Use its authority under Section 1042 of the Dodd-Frank Act to help preserve the coherent development of federal consumer financial law and avoid a fragmented, state-by-state patchwork;

• Limit matters requiring attention (MRAs) to substantive legal violations, rather than using supervisory tools to impose new expectations outside the rulemaking process; and
• Direct more supervisory, enforcement, and consumer education resources toward frauds and scams, particularly in nonbank channels where consumer harm is growing.

These steps would help ensure the CFPB functions as a more effective and durable regulator while better protecting consumers in a rapidly evolving financial marketplace.

Read CBA's full comment letter HERE.

CBA Advocacy

• To read CBA's white paper calling for CFPB reforms to transform the CFPB into the credible, durable regulator that consumers deserve, click HERE.
• Last August, Johnson penned an op-ed in American Banker highlighting the unique opportunity lawmakers and the Trump Administration have to reform the Consumer Financial Protection Bureau (CFPB) into the credible, durable agency that hardworking Americans deserve. To read the op-ed, click HERE.
• To watch Johnson's full opening remarks in a July 2025 Congressional testimony on the lessons learned from the Dodd-Frank Act, click HERE. To read Johnson's full written testimony from the hearing, click HERE.
• To read CBA's "Vision for America - A Bank Policy Agenda for All," which outlines the retail banking industry's priorities, beliefs, and positions on a number of consumer-focused financial services policy issues, click HERE.
• To read CBA President and CEO Lindsey Johnson's January 2025 letter to the editor in The Wall Street Journal calling for a reboot at the CFPB, click HERE.