In early November 2025, the Consumer Financial Protection Bureau (CFPB) formally terminated its consent order against TransUnion after determining that the credit bureau had met the conditions required under the agreement. The original order, issued in October 2023, stemmed from findings that TransUnion failed to promptly place or lift credit security freezes while assuring consumers that the freezes were active, among other violations of the Consumer Financial Protection Act.
According to the CFPB’s termination notice dated Nov. 3, 2025, TransUnion paid a $5 million civil money penalty, provided redress payments, and implemented measures designed to prevent similar issues going forward. The order was lifted by Acting CFPB Director Russell Vought.
A Changing Leadership LandscapeÂ
Vought is currently reviewing the bureau’s enforcement priorities and overseeing its regulatory agenda. His term as acting director is set to expire in early December 2025, and Stuart Levenbach, a senior official at the Office of Management and Budget, has been nominated to serve as the CFPB’s permanent director.Â
Under the Federal Vacancies Reform Act, Levenbach’s nomination allows Vought to continue serving as acting director for an additional 210 days. This extension effectively preserves the current leadership structure into mid-2026, providing additional time for the bureau to move forward with its ongoing initiatives.Â
Regulatory Priorities and Shifting Enforcement ApproachesÂ
Among the CFPB’s current rulemaking priorities are proposed changes to the Equal Credit Opportunity Act (ECOA). The bureau is also preparing to rescind a final rule that would have created a registry of nonbanks subject to enforcement actions, as well as a proposed rule that would have required nonbanks to report information on certain terms and conditions used in form contracts.Â
On the enforcement side, the bureau has shifted its approach to cases involving the Buy Now, Pay Later (BNPL) sector. Recent statements indicate that CFPB enforcement and supervisory resources will target what the agency views as the most pressing risks to consumers, including those affecting servicemembers and veterans.Â
Budget Concerns, but No Change to Existing RulesÂ
Amid these developments, the CFPB has stopped drawing funds from the Federal Reserve. Court filings indicate that the bureau could exhaust its remaining revenue by the end of the year. Despite these financial concerns, there has been no change to existing consumer-protection regulations.Â
All current CFPB rules remain in force, and state attorneys general continue to hold enforcement authority under many consumer financial protection laws. Additionally, various federal statutes allow consumers to bring private lawsuits. As a result, compliance obligations and legal exposure for financial services companies persist even if federal enforcement activity slows.Â
Author:Â Jennifer Evancic
Jennifer.Evancic@ResourceManagement.com
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