CFPB (agency-wide action)
Beginning February 10, 2025, CFPB Acting Director Russell Vought issued a stop-work order that effectively halted the agency's enforcement, supervision, and consumer complaint operations. Probationary and term employees were terminated, including the Private Student Loan Ombudsman. The CFPB could voluntarily dismiss pending enforcement lawsuits, cease ongoing investigations, void prior consent orders with refunds of penalties, and invalidate regulations or guidance from Director Chopra's tenure. No combined financial recoveries from enforcement had occurred since September 2022, signaling a broader enforcement slowdown. For the BaaS industry, this created a significant supervisory vacuum, as the CFPB had been a primary federal regulator overseeing bank-fintech consumer protection compliance. The March 28 injunction partially reversed these actions but did not mandate resumption of supervisory exams.
Verified from source: The page confirms that CFPB Acting Director Vought issued a February 10, 2025 stop-work order, placed employees on administrative leave, and terminated probationary employees, effectively halting CFPB operations. Judge Jackson's March 28, 2025 preliminary injunction ordered reinstatement of terminated employees and rescission of the stop-work order.
- BaaS sponsor banks and their fintech partners face reduced federal oversight during the CFPB enforcement pause
- Prior consent orders involving fintech-bank partnerships could be voided, releasing banks from prior compliance obligations
- The supervisory vacuum may embolden riskier fintech-bank arrangements in the near term
- State regulators may attempt to fill the gap with their own enforcement actions