CFPB Plans Comprehensive Review and Rescinding of Past Guidance

The Consumer Financial Protection Bureau (CFPB), under Acting Director Russell Vought, has announced a major internal shift by discontinuing the use of regulatory 'guidance' that previously created de facto rules without public input, moving instead to strictly adhere to the notice-and-comment rulemaking process required by the Administrative Procedure Act. Vought criticized past practices for imposing obligations on private parties outside the formal regulatory process and called for a comprehensive review and possible rescission of existing guidance documents deemed unlawful. Future CFPB guidance must clearly state its nonbinding nature, and noncompliance will not trigger enforcement actions. Simultaneously, the CFPB is scaling back its enforcement efforts in areas such as student loans, medical debt, and digital payments, redirecting resources toward protecting military personnel and focusing supervision on the largest banks. These changes come amid ongoing political pressure to reduce or even dissolve the agency, reflecting a broader realignment of its priorities. The CFPB's decisions have already prompted the revocation of an advisory opinion on medical debt following legal challenges.