The CFPB’s New Direction in 2025
If you run a small or mid-sized collection agency, 2025 feels like a regulatory reset. With President Trump back in office, the Consumer Financial Protection Bureau (CFPB) is once again under scrutiny — and its enforcement authority under the Dodd-Frank Consumer Financial Protection Act (CFPA) is being reshaped.
The administration’s priorities are clear: fewer sweeping rulemakings, lighter oversight for nonbank providers, and a return to “enforcement through litigation” rather than regulation.
Early moves from Washington confirm this shift:
- The House Financial Services Committee has already voted to review several final rules issued under the Biden-era CFPB.
- The Trump administration is promoting deregulation across financial institutions, particularly around mortgage servicing, student loans, and digital payments.
- Analysts predict a rollback of broad UDAAP (Unfair, Deceptive, or Abusive Acts or Practices) interpretations — one of the Bureau’s most controversial tools.
That doesn’t mean it’s open season for collectors, though. What’s happening is a refocusing of enforcement priorities: less red tape, more case-by-case action, and stronger collaboration between state regulators and state attorneys general.
What Enforcement Looks Like Now
1. Narrower Federal Oversight, Sharper State Enforcement
Federal consumer financial laws aren’t disappearing, but their enforcement will become more targeted. The CFPB’s staffing and budget have both been trimmed in 2025, meaning fewer proactive investigations and fewer new proposed rules.
Instead, you’ll see:
- Selective CFPB enforcement actions focused on repeat offenders.
- Greater reliance on state-level oversight in markets like New York, California, and Washington.
- Coordination between state attorneys general and the Federal Trade Commission (FTC) for multi-state actions involving credit reporting, student loan servicing, and digital remittances.
This state-federal dynamic means agencies operating across multiple jurisdictions must ensure their systems handle both federal consumer financial laws and stricter state law requirements.
For example, New York’s consumer protection laws now expand credit card disclosure rules and limit fees, while Washington’s “3-in-7” contact cap remains stricter than the federal Regulation F “7-in-7” rule.
Tip: Modern platforms automatically enforce both federal and state-specific rules — from mini-Miranda disclosures to contact frequency caps — reducing risk for agencies managing multi-state portfolios.
Learn more: CFPB Under Trump: Reg F’s Future in 2025
2. Expect Fewer New Rules — But Faster Litigation
Under Director Rohit Chopra, the CFPB leaned heavily on rulemaking and legal theories that expanded its reach into areas like small business lending, credit reporting, and digital remittances.
Under the Trump administration, those priorities are being reevaluated. Several pending rules, including updates to TILA (Truth in Lending Act), FCRA (Fair Credit Reporting Act), and remittance disclosures, are now on hold or under reconsideration.
Instead, the CFPB is expected to focus on:
- Legacy consent orders that remain under monitoring.
- Targeted enforcement for data misuse, consumer deception, or unauthorized fees.
- Selective cases that deliver clear political or consumer wins — such as those involving servicemembers, veterans, or elderly borrowers.
Agencies should anticipate fewer headlines about sweeping proposed rules and more about district court filings where the CFPB pursues individual companies under established precedent.
3. UDAAP and Fair Lending — Still on the Radar
Even with deregulation, UDAAP and fair lending remain pillars of federal oversight. The CFPB’s statutory authority under Dodd-Frank still allows it to pursue depository institutions, lenders, and nonbank providers for deceptive or discriminatory practices.
What’s changing is the scope: enforcement will focus on clear-cut violations rather than ambiguous interpretations.
For debt collectors, this means:
- Accurate and transparent loan servicing and loan origination documentation.
- Avoiding misrepresentations in credit reporting or consumer data handling.
- Following through on any consent order obligations from prior enforcement periods.
If you handle student loans, credit cards, or small business lending, expect heightened scrutiny from both the Department of Education and state attorneys general, as these remain politically sensitive sectors even under a deregulatory agenda.
4. State Attorneys General Are the New “Mini-CFPBs”
With the CFPB pulling back, state enforcement is filling the vacuum.
In 2025, states like New York, California, and Illinois have reaffirmed their authority to enforce federal consumer financial laws using their own statutes. Some have even created joint CFPB-state task forces for faster coordination on high-impact cases.
For debt collection agencies, this means compliance isn’t just about Reg F anymore. It’s about maintaining a compliance management framework that automatically adapts to each debtor’s jurisdiction.
Agencies using outdated systems often struggle to enforce differing contact rules, disclosure timing, or validation requirements across states. Modern cloud-based platforms can automate these variations, applying state-aware logic and ensuring that every communication, notice, and payment record is compliant and audit-ready.
Learn more: Modern Debt Collection Solutions | State Laws Agencies Must Know
5. New Areas of Focus: Data, Automation, and “Junk Fees”
Even as the CFPB tightens its budget, certain enforcement themes remain bipartisan and continue to draw attention:
- Consumer Data Privacy: Unauthorized sharing or breaches of consumer information still trigger UDAAP or FCRA investigations. Agencies must be able to prove data security and consent tracking in every consumer interaction.
- AI and Automation: Automated call systems and AI voice agents are under new scrutiny. Agencies must ensure all automated outreach complies with Reg F, TCPA, and FDCPA contact caps while maintaining full audit logs.
- Fee Transparency: Expect continued focus on “junk fees” — such as hidden convenience fees or ambiguous payment surcharges — especially in digital payments and remittances.
- Servicemember Protections: The CFPB continues to monitor debt collection and lending practices involving military personnel and veterans, often in collaboration with the Department of Defense (DoD) and the Veterans Administration (VA).
- Mortgage Servicing and Loan Errors: Incorrect balances, late-payment fees, and escrow mistakes remain frequent drivers of consumer complaints and enforcement actions by the CFPB and HUD.
In other words, even in a friendlier regulatory environment, risk still exists; it’s just more focused.
How Agencies Can Prepare (Without Losing Sleep)
1. Maintain a Real Compliance Management System
Even if federal agencies ease enforcement, don’t downgrade compliance. CFPB enforcement authority is cyclical, and courts can swing either way.
Use systems that automatically:
- Enforce Reg F and FDCPA timing rules.
- Log all communications with timestamps.
- Centralize audit trails for both federal and state enforcement reviews.
2. Build Redundancy for State Law Compliance
If you collect across multiple states, use technology that adjusts automatically for regional state law differences, such as contact frequency limits, disclosure templates, and validation deadlines.
3. Document and Automate
The safest agencies are the most documented. Tools that integrate AI voice agents, no-code workflow builders, and real-time audit logs help prove every disclosure, consent, and payment event was handled correctly.
4. Stay Audit-Ready
Even if you’re not facing a federal exam, creditors increasingly demand proof of compliance. Automated reporting dashboards and performance summaries demonstrate operational transparency, a critical trust signal when courting new clients.
5. Keep an Eye on the Courts
Recent district court rulings have questioned parts of the CFPB’s statutory authority, creating uncertainty around its funding and legal theories for enforcement. While these challenges may delay certain actions, agencies should prepare for “snap-back” enforcement if the Bureau regains full autonomy.
The Takeaway: Compliance Is Still a Competitive Advantage
Regulatory pendulums swing, but reputation lasts. Even in a deregulatory climate, clients prefer agencies that are:
- Transparent
- Automated
- Audit-ready
- Proactive about compliance
Maintaining a modern compliance management foundation isn’t just risk mitigation; it’s also a growth strategy. Agencies that can demonstrate airtight controls, accurate reporting, and consumer-friendly outreach will win bigger contracts while competitors play catch-up.
If your agency is still juggling outdated systems or disconnected tools, now’s the time to modernize. Platforms built for modern compliance help you enforce federal consumer law, track state-specific enforcement, and automate what used to take hours of manual effort.
Disclaimer: This article is for informational purposes only and does not constitute legal advice. Debt collection agencies should consult with legal counsel to ensure compliance with all applicable federal and state regulations.
