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Changes from the Top: The 2nd Trump Administration’s Efforts to Sharply Limit the CFPB and the Growing Role of State AGs and other Actors in the Consumer Protection Landscape

Author: Elizabeth J. Ireland.; Starling Gamble.

Source: Volume 41, Number 05, May 2025 , pp.47-52(6)

Abstract:

This article explores some of the key changes for financial services enforcement in the beginning of the second Trump presidency. During this time, the administration has emphasized certain enforcement areas — such as de-banking and lending to servicemembers — while also revamping one of the primary mechanisms through which financial services institutions are investigated with drastic changes to the Consumer Financial Protection Bureau. The authors contemplate what may come next — and how other actors may take a more leading role.

Keywords: “Flood-the-Zone” Changes in Regulatory Agencies; Administrative Procedure Act; NY Department of Financial Services (“NY DFS”); Miss. Bankers Ass’n v. Consumer Fin. Prot. Bureau

Affiliations: 1: Winston & Strawn LLP; 2: Winston & Strawn LLP.