As Goodwin anticipated in our 2024 Year in Review, 2025 witnessed a fundamental shift in the consumer financial services regulatory landscape. The frenzied federal enforcement activity that characterized 2024 gave way to sweeping federal retrenchment, most notably by the Consumer Financial Protection Bureau (CFPB). The CFPB’s year was highlighted by the rescission of multiple consent orders, a dramatic drop in enforcement actions, a pause of large-scale supervisory activity, and legal challenges to its attempt to fire most staff.
Across the board, federal financial services regulation was uneven, with a clear split between active and dormant agencies. Unlike the CFPB, the Federal Trade Commission (FTC) stayed active, particularly in consumer protection, advertising, and fintech practices, even as it reconsidered or pulled back certain artificial intelligence–related actions. Banking regulators including the Federal Reserve, the Office of the Comptroller of the Currency (OCC), and the
