Federal regulators are doing much less policing of collectors than a few years ago, so private enforcement through individual cases matters more for Texans.
The CFPB rescinded all prior supervision and enforcement priority documents, ordered a 50% cut in supervisory 'events,' shifted focus to depository institutions and actual fraud with identifiable victims, and favored redress over penalties. It listed 'FDCPA/Reg F relating to consumer contracts/debts' and FCRA furnishing violations as priority areas, while deprioritizing medical debt and student loans.
- Citation
- Memorandum from Mark R. Paoletta, CFPB Chief Legal Officer, '2025 Supervision and Enforcement Priorities' (Apr. 16, 2025); 90 Fed. Reg. 38418 (Aug. 8, 2025) (ANPR)
- Court or agency
- Consumer Financial Protection Bureau
- Date
- April 16, 2025
- Law
- FDCPA, Regulation F, FCRA
Summary
In 2025 the CFPB changed course sharply. An April 16, 2025 memo set narrower priorities, the Bureau dropped or ended a number of matters, and in August 2025 it asked whether to raise the size threshold for supervising debt collectors. Debt collection and credit-reporting violations remained on the list of stated priorities, but on a much smaller footprint.
Background
From 2020 through 2024, the CFPB was the most active federal regulator of debt collectors. It wrote Regulation F, supervised larger collection agencies, and brought major cases against the largest debt buyers.
In February 2025, Russell Vought became Acting Director, and the Bureau’s direction changed quickly.
What the order requires
The April 16, 2025 priorities memo. The CFPB’s Chief Legal Officer, Mark R. Paoletta, sent staff a memo that:
- rescinded “all prior enforcement and supervision priority documents”;
- directed a 50% reduction in supervisory “events” such as exams;
- shifted the focus back toward banks and other depository institutions and away from non-banks;
- directed the Bureau to focus on “actual fraud” with identifiable victims and measurable damages;
- favored getting money back to consumers over penalties;
- listed priority areas: mortgages first, then FCRA/Regulation V furnishing violations, “FDCPA/Reg F relating to consumer contracts/debts,” fraudulent overcharges and fees, and data-security failures; and
- deprioritized several areas, including medical debt and student loans.
Other 2025 changes.
- On May 12, 2025, the CFPB withdrew 67 guidance documents, including its advisory opinions on pay-to-pay fees and time-barred debt.
- The CFPB terminated a number of existing consent orders before their scheduled end. For example, it terminated a mortgage-servicer order against Fay Servicing in July 2025.
- On August 8, 2025, the CFPB published an advance notice of proposed rulemaking on whether to raise the threshold for supervising debt collectors. Currently, a collector with more than $10 million in annual receipts from consumer debt collection is a “larger participant” subject to CFPB supervision. The notice said that threshold may cost more than it is worth.
- On October 29, 2025, the CFPB rescinded its registry of non-bank companies subject to agency and court orders (90 Fed. Reg. 48760).
Litigation over the Bureau’s plan to lay off most of its staff, National Treasury Employees Union v. Vought, was still pending in the federal courts in Washington, D.C. as of this update.
Our take
On paper, debt collection is still a CFPB priority. In practice, with far fewer exams, a smaller staff and a stated preference for leaving matters to the states, consumers should expect few new federal actions against collectors. The large orders already in place, such as the 2023 Portfolio Recovery Associates order, matter more than ever as benchmarks.
None of this changes the law that applies in a courtroom. The FDCPA, Regulation F and the Fair Credit Reporting Act still give consumers their own right to sue for violations, and the Texas Debt Collection Act provides state-law remedies.
What it means if you’re sued in Texas
For a Texan being sued or harassed over a debt, the practical effect is that defenses and counterclaims raised in your own case carry more weight. A complaint to the CFPB or the Texas Attorney General is still worth filing, but it is not a substitute for answering a lawsuit by the deadline.
If a collector has violated your rights, a free case review is available.
Takeaway
Do not count on a federal agency to step in on an individual collection problem. Consumers keep their own rights to sue under the FDCPA and the Texas Debt Collection Act.
Sources
Primary authority
- 2025 Supervision and Enforcement Priorities memo, as filed in NTEU v. Vought, No. 1:25-cv-00381 (D.D.C.), Dkt. 109 (Orrick InfoBytes copy)
- Defining Larger Participants of the Consumer Debt Collection Market, ANPR (Federal Register, 90 Fed. Reg. 38418)
- Order terminating Fay Servicing consent order, July 2025 (CFPB)
Secondary sources
- Shifting Priorities: Bureau Memorandum Provides Insight Into New Era for CFPB (Goodwin)
- D.C. Circuit Hears En Banc Argument in NTEU v. Vought (Ballard Spahr, Consumer Finance Monitor)
This summary and analysis are general information, not legal advice. Later decisions, amendments or agency actions may change the law; check the current status before relying on it.