2025 was an interesting year. We found out that it was way easier to rob the Louvre than anyone could’ve ever have expected, the term “6, 7” was reimagined to have nothing to do with numbers, and the financial services industry continued to evolve with rapidly developing regulatory changes.
As we look back over the past year, the one theme that remains consistent is deregulation. The current administration has proposed or instituted board-sweeping changes and all have had a common theme: deregulation.
So, what happened this past year and where is the industry at now?
In February, President Trump dismissed Rohit Chopra from his position as Director of the Consumer Financial Protection Bureau (CFPB) and nominated Russell Vought as acting CFPB director. To date, Vought remains the acting director for the CFPB.
Following the changes, the CFPB began withdrawing rules or eliminating guidance. Notably, the CFPB withdrew 67 pieces of guidance this past May. The withdrawal included 8 policy statements, 7 interpretive rules, 13 advisory opinions, and 39 other pieces of guidance. The withdrawal included the elimination of several Unfair and Deceptive Practice guidance for certain debt collection practices, promotional APR rates in credit card advertisements, and consumer reviews.
Then, as part of the Tax Reconciliation Act, the CFPB experienced a budget cut. According to the terms of the act, the CFPB’s total operating budget was decreased from 12% of the Fed’s inflation-adjusted total operating expenses to 6.5% of the Fed’s inflation-adjusted total operating expenses. The decrease has resulted in significant numbers of staff layoffs and, ultimately, a decrease in labor.
In an interesting plot twist, the CFPB also resurrected the Personal Data Financial Rights (“open-banking”) rule from its procedural withdrawal in court. In August, the CFPB issued an Advanced Notice of Proposed Rulemaking for the open-banking rule, with comments due to the CFPB in October. To date, the proposed rule has yet to be advanced in the rule-making process. However, in the beginning of December, the Bureau noted that it will issue “interim” rules until more development can be made.
The CFPB also proposed a rule designed to extend the compliance deadlines for the Small Business Data Collection Rule, also known as Section 1071. If the rule were to be finalized, the rule would extend current compliance deadlines to begin on July 1, 2026, with tiered compliance deadlines based on certain criteria following the July 1 deadline.
More recently, in November, the CFPB issued a proposed rule removing the “disparate impact” standard from Regulation B, the section of the Code of Federal Regulations which implements the Equal Credit Opportunity Act. According to the provisions of the proposed rule, the Bureau clarified that Regulation B does “not authorize disparate-impact liability (effects test), [the Bureau] further define[d] discouragement, and add[ed] prohibitions and restrictions for special purpose credit programs.”
Finally, also in November, the CFPB filed a court notice stating that it is legally unable to draw funds from the Federal Reserve. The inability has a significant impact on the CFPB’s funding and ability to take part in continued operations. Estimates suggest that the CFPB will not be able to continue after the beginning of 2026.
The beginning of the year was also a time of personnel changes at the NCUA. Beginning in April, the Trump Administration dismissed both former Chairman Todd Harper and Board Member Tanya Otsuka. While both former board members tried to appeal the decision to the court, asking the U.S. Supreme Court to grant review of the case. They were both unsuccessful. To date, the U.S. Supreme Court recently denied review to both former board members.
Meanwhile, now-Chairman Kyle Hauptman was designated as Chairman of the NCUA in January 2025, and Chairman Hauptman’s term expired in August. However, he remains the Chairman of the NCUA until another chair is designated.
To date, the two board positions left vacant by the dismiss of Harper and Otsuka have yet to be filled.
In addition to personnel changes, the NCUA also is following the trend of deregulation.
From a regulatory standpoint, the NCUA opened the year by announcing that they would no longer be publishing Overdraft and Non-Sufficient Funds (NSF) fees. However, to date, while the NCUA is no longer publishing those fees, it will continue to collect that data through Supervisory Examinations.
In June, the NCUA published an exemption from certain Customer Identification Program (CIP) requirements. According to the inter-agency guidance, credit unions can now request customer identification information from third-parties rather than relying on the answers from the customers themselves.
Then, in July, the NCUA began their Economic Growth and Regulatory Paperwork Reduction Act review (EGRPRA). This was a voluntary process that the NCUA began and is meant to identify rules that are “outdated, unnecessary, and unduly burdensome to federally insured credit unions.”
In the fall, the NCUA issued a Letter to Credit Unions stating that in compliance with the Executive Order 14281 Restoring Equality of Opportunity and Meritocracy, it would be prohibiting it’s examiners from requesting, reviewing, or concluding on or following up on:
However, the NCUA will continue to regularly conduct fair lending risk assessments, analyzing Home Mortgage Disclosure Act data for possible evidence of disparate treatment, conducting risk-based fair lending examinations, and will take appropriate action if evidence of disparate treatment is found.
Later in the fall, Chairman Hauptman issued a statement indicating a policy shift in NCUA enforcement. Going forward, the NCUA will cease to regulate through enforcement. The statement included the following provisions:
If the NCUA finds a harmful practice that threatens our mission or is otherwise injurious or abusive, and it is not currently addressed by law or regulation, then our next step is to consider rulemaking or other remedy. As is the norm in America, the sequence of events at the NCUA to first publish rules and then to enforce them.”
Finally, the NCUA recently issued a deregulation project. The project is intent on “ensur[ing] the regulations are focused on the safety, soundness, or resilience of credit unions. Further, NCUA will propose changing or removing regulations that are:
The project will review the regulations “housed” in Title 12, Chapter 7 of the Code of Federal Regulations.
The list that is included in this article is by no means comprehensive. Federal regulators have consistently been withdrawing or eliminating guidance that has been deemed outdated, overly burdensome, or irrelevant. As 2026 approaches, it is likely this deregulation trend will continue.
Have questions or want to know more? Contact ViClarity’s Compliance Services team at compliancesupport@viclarityus.com.
(Authored by ViClarity)
For more information, email Heather Line.
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