Donald Trump’s return to the White House has led to unprecedented challenges for the US consumer finance watchdog, culminating in this month’s announcement that it will stop receiving federal funds. But Lexology PRO analysis shows that the real collapse in enforcement activity began months ago.
Key takeaways
- CFPB enforcement activity has collapsed under the Trump administration, with no new investigations or orders announced since the Biden-era director’s departure.
- With an announcement it cannot legally source funds for next year, the bureau’s functions are likely to cease in a confirmation of regulatory trends.
- The CFPB’s situation does not necessarily reflect the Trump administration’s approach to financial regulation more generally.
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The CFPB this month informed a federal court that it cannot legally request funding from the Federal Reserve, which could see it stop functioning from next year.
But data from Scanner, Lexology PRO’s automated regulatory monitoring tool, shows that the CFPB had effectively ceased to function as an enforcement agency several months beforehand.
Analysis reveals a highly active regulator disintegrating in tandem with the change in administration. The total number of enforcement measures and the volume of penalties and redress imposed collapsed immediately after the Trump administration began in January 2025.
The watchdog was created by the post-financial crisis Dodd-Frank reforms, and has returned $19.7 billion in consumer redress and handed out more than $5 billion in civil penalties since its inception. Republicans have long been critical of the regulator, regularly calling it unaccountable and politicised.
Its inherent political divisiveness makes any direct read-across to other federal regulators difficult, with the Securities and Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), Office of the Comptroller of the Currency (OCC) and others not facing imminent destruction despite their shifting attention towards deregulation and a pro-business, pro-innovation focus under the Trump administration.
Enforcement activity falls under the Trump administration
Enforcement activity has fallen substantially in 2025, especially since Trump’s inauguration. While the CFPB was relatively active throughout last year, it launched an increased number of lawsuits in December 2024 following Trump’s election victory on 5 November.
With 28 enforcement cases announced in 2023 and 36 in 2024, only three have concluded during this administration – including a $9 million settlement with FirstCash over Military Lending Act violations and a $2.025 million fine against remittance provider Wise. The latter was announced during the brief period that Trump and Biden-era director Rohit Chopra’s tenures coincided, which the CFPB later cut by 98%.
There has been an acute fall in activity in 2025, with Chopra announcing a flurry of enforcement action in the final days of the Biden administration – most likely anticipating that he would soon be removed and that his agenda would be scuppered.
The final Chopra enforcement sprint included a settlement with Cash App’s parent company Block for $175 million on 16 January, and a $12.8 million order against Honda’s auto financing arm on 17 January.
Of the 11 enforcement-related announcements in 2025 so far, nine (82%) were in January – and eight (73%) before Trump’s inauguration on 20 January. Aside from the FirstCash settlement and the later amended Wise penalty, the CFPB has also said it will deprioritise enforcement against small loan providers and buy now pay later (BNPL) companies under the leadership of Trump protegé Russell Vought. It has so far only settled those two claims during the Trump administration, and has not announced a single new enforcement measure.
As enforcement falls to almost nothing, so have penalties
The cumulative penalty totals including consumer redress per quarter since Q1 2023 show little consistency, but 2023 and 2024 saw similar trends with peaks towards the end of each year. The outlier was 2025, where the CFPB announced a flurry of enforcement action in January ahead of the changeover of power.
While grouping by quarter has mitigated some of the more drastic variations, the apparent inconsistency is largely a result of some very high fines against large entities rather than a lull in the volume of enforcement measures announced each year.
The data further highlights the bureau’s non-existent enforcement since then.
The very high totals in some quarters were marked by an individual, dominant fine. For example, in Q3 2023 the agency fined Bank of America over $170 million for charging junk fees and creating fake accounts and in Q4 2024 it fined Apple and Goldman Sachs nearly $90 million in total for failures on Apple Pay. There has been no such case during the second Trump presidency.
| Year | Number of penalties | Cumulative value ($million) | Average ($million) | Highest (redress plus civil penalty, $million) |
| 2023 | 21 | 437.5 | 20.833 | 170.4 (Bank of America) |
| 2024 | 23 | 412.729 | 17.985 | 120 (Navient) |
| 2025 | 7 | 218.025 | 31.153 | 175 (Block) |
| 2025 (Trump administration) | 2 | 9.045 | 4.5225 | 9 (FirstCash settlement) |
While the number of penalties imposed, their cumulative value and the average penalty were all comparable across 2023 and 2024, Scanner data shows a steep fall in penalties in 2025, even including the pre-inauguration rush in January. The average penalty has been skewed by Cash App parent Block’s fine days before Trump was sworn in.
Does the CFPB offer a cautionary tale to other federal regulators?
The CFPB’s plight shares similarities with other US financial regulators, but its circumstances are ultimately unique.
While the Trump administration has prioritised deregulation across the complicated federal regulatory framework, its attacks on the CFPB have been existential. Republicans have long complained the agency’s structure makes it a uniquely unaccountable and politicised agency. Unlike other regulators such as the SEC, CFTC and Federal Trade Commission (FTC), its sole director has extensive authority, and it is not accountable to Congress in the same way others are.
The CFPB’s unusual structure means it is difficult to read much of its current plight across to other financial regulators – although enforcement has dropped across the board. For example, the SEC has dropped many of its Biden-era crypto litigation cases, with the Trump administration taking a hands-off approach to digital assets innovation.