CFPB Terminates Consent Order Against Credit Union Early

Sheppard Mullin Richter & Hampton LLP

On July 18, the CFPB terminated a 2024 consent order against a credit union after concluding that the entity had satisfied certain monetary and compliance-related requirements. The original order, issued in October 2024, alleged violations of the Consumer Financial Protection Act arising from the credit union’s 2022 banking platform conversion, which left members unable to access their online and mobile accounts for extended periods of time.

According to the Bureau, the credit union fulfilled “certain obligations,” including payment of a $1.5 million civil money penalty and implementation of partial redress. The credit union conducted an audit to confirm refunds for members who submitted requests, but the Bureau did not state whether consumers eligible for reimbursement but who failed to file claims received any redress. The termination also waived any alleged non-compliance with the order’s redress or audit provisions.

The CFPB formally ended the consent order ahead of schedule and waived ongoing oversight requirements, including monitoring and reporting obligations.

Putting It Into Practice: This termination is part of a growing trend under current CFPB leadership to roll back or end prior enforcement orders before their scheduled expiration dates (previously discussed here and here). Financial institutions operating under consent orders may reassess their compliance strategies in light of this evolving approach but should remain prepared for possible shifts in enforcement rigor under future leadership.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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