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ARTICLE · 12 AUGUST 2025

Potential For Increased State Consumer Finance Enforcement

Mayer Brown
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A decrease in Consumer Financial Protection Bureau ("CFPB") enforcement actions may motivate state regulators to fill the enforcement void.

United StatesConsumer Protection
Christa Bieker
Christa Bieker
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A decrease in Consumer Financial Protection Bureau ("CFPB") enforcement actions may motivate state regulators to fill the enforcement void. We have not seen a dramatic increase in state actions to date, but it will necessarily take states time to hire staff and initiate investigations that will ultimately lead to public settlements. Notably, there have been reports of former CFPB staff joining various state regulator and attorney general offices.

While states have their own consumer financial laws that they enforce, including UDAP/UDAAP prohibitions, they could also enforce certain federal consumer financial laws. With some limitations on actions against national banks or federal savings associations, Section 1042 of the Dodd-Frank Act provides that state attorneys general may bring a civil action to enforce Title X of the Dodd-Frank Act or regulations issued under Title X of the Dodd-Frank Act.1 Similarly, Section 1042 provides that a state regulator may bring a

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