The CFPB may be frozen, but RESPA hasn't gone away
Briefly

The recent decision to skip a funding allotment for the Consumer Financial Protection Bureau (CFPB) is seen by enforcement experts as unlikely to impede compliance with key federal statutes like RESPA and UDAAP. Historical precedents show previous administrations, such as under Mick Mulvaney, did not experience significant operational challenges after skipping funding rounds. The CFPB is mandated to seek necessary funding, and failure to do so may result in legal repercussions, even as experts assert the signaling effect of the pause does not imply a relaxed enforcement stance on compliance regulations.
While some may think that the pause on CFPB activities and Vought's funding decision may signal that it is OK for companies to skirt certain rules like RESPA and UDAAP, enforcement experts don't believe that is the case.
Experts noted that the pause Bessent put in place is typically used by a new administration to review all open enforcement matters before deciding which to continue pursuing.
In a post on X, Vought called the bureau's current balance of $711.6 million excessive in the current fiscal environment, but Ehrlich noted that it could fund the bureau for a while.
The Consumer Financial Protection Act states that the bureau's director must request the funds that are reasonably necessary to carry out the functions of the bureau.
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