WASHINGTON—Both America’s Credit Unions and the American Bankers Association have filed comment letters with the Consumer Financial Protection Bureau regarding its 2026–2030 strategic plan.
In its letter, America’s Credit Unions said the CFPB should prioritize consumer protection efforts where risks are greatest, particularly among nonbank lenders and fintech firms, rather than increasing oversight of credit unions, which it said are already subject to extensive supervision.
Key Recommendations
The organization outlined several recommendations for the Bureau’s strategic direction, including:
- Focus enforcement on higher-risk entities: Direct supervisory and enforcement resources toward nonbank lenders and fintech companies rather than credit unions.
- Clarify UDAAP standards: Define the “abusiveness” standard under unfair, deceptive, or abusive acts and practices through formal rulemaking.
- Tailor regulations for credit unions: Use existing authority under the Dodd-Frank Act to ensure rules appropriately reflect the structure and mission of credit unions.
- Return to formal rulemaking processes: Rely on notice-and-comment procedures and comply with Small Business Regulatory Enforcement Fairness Act requirements.
- Reform enforcement procedures: Improve Civil Investigative Demand processes and broader enforcement practices to ensure due process protections.
Broader Concerns
America’s Credit Unions also reiterated broader structural concerns with the CFPB, stating that consumers and financial institutions would be better served if the bureau were funded through the congressional appropriations process and governed by a bipartisan, multi-member commission rather than a single director.
In its letter, ACU said these changes would help create a more balanced regulatory environment, support innovation and competition, and ensure that consumer protection efforts are focused on areas of greatest risk.
ABA Wants Deregulation Prioritized
Separately, the American Bankers Association (ABA) is urging the Consumer Financial Protection Bureau(CFPB) to prioritize deregulation, statutory clarity and fraud prevention in its draft Strategic Plan for fiscal years 2026–2030.
In a comment letter the ABA said it supports the CFPB’s focus on reducing regulatory burdens, improving transparency in rulemaking and strengthening consumer protections through targeted supervision, but called for refinements to ensure balanced oversight and continued market competition.
The trade group said excessive compliance costs can limit access to financial services and reduce banks’ ability to serve consumers, adding that rulemaking — rather than guidance or enforcement actions — should be the primary tool for shaping policy.
ABA’s Recommendations
The ABA’s recommendations include:
- Support for deregulation: The ABA endorsed efforts to review and streamline existing regulations, arguing that unnecessary rules increase costs for consumers and limit access to banking services.
- Rulemaking over enforcement: The group said policy changes should rely on formal rulemaking with public input and cost-benefit analysis, rather than “subregulatory” guidance.
- Statutory limits: The ABA urged the CFPB to remain within clearly defined legal authority, criticizing past efforts it said expanded oversight through “novel legal theories.”
- Consumer complaint database reforms: The association supported efforts to remove inaccurate or fraudulent complaints, including those tied to so-called “credit washing” schemes.
- Fraud and scam prevention: The ABA called fraud education the top consumer protection issue and encouraged coordination with agencies including the FTC and FCC.
- Supervision focused on consumer harm: The group backed a shift toward addressing measurable harm to identifiable consumers rather than technical violations, and urged the CFPB to formalize that approach through rulemaking.
- Eliminating duplicative oversight: The ABA said overlapping supervision by the CFPB and prudential regulators is inefficient and should be reduced through coordination.
Caution Urged
At the same time, the ABA cautioned against reducing oversight of nondepository financial firms, warning that doing so could create regulatory gaps and undermine consumer protections.
The group said robust federal supervision of nonbanks is essential to ensure consistent enforcement of consumer financial laws and fair competition, particularly as fintech firms expand into lending and other services.
The ABA also urged the CFPB to incorporate implementation of a recent executive order on mortgage reform into its strategic plan, calling for a comprehensive modernization of mortgage regulations, including disclosures, data reporting and digital processes.
