The Consumer Bankers Association (CBA) offered recommendations and feedback for the Consumer Financial Protection Bureau (CFPB) on its Draft Strategic Plan for Fiscal Years 2026–2030.
The CBA is urging the CFPB to finalize a plan that is firmly grounded in the Dodd-Frank Wall Street Reform and Consumer Protection Act, focused on tangible consumer harm, and committed to evenhanded oversight across banks and nonbanks.
“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,” CBA President and CEO Lindsey Johnson said. “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.
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, in a new statement:
Overall, the CBA supports several key elements of the CFPB’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.
However, the CBA 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.
“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,” CBA officials wrote in a comment letter.
The CBA is recommending that the CFPB:
- 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.
The association said that 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.