Withdrawal of Guidance and Advisory Opinions

• Acting Director Russell Vought announced the withdrawal of 67 guidance documents on May 12, 2025
• Withdrawals include policy statements, interpretive rules, advisory opinions, and other guidance documents

The Consumer Financial Protection Bureau (CFPB) announced the revocation of nearly 70 interpretive rules, advisory opinions, and guidance documents in a sweeping move on May 12, 2025. The Federal Register Notice brings to an end an era of CFPB guidance that has been criticized for its overbreadth and lack of clarity. The move marks a significant shift in the CFPB’s approach to regulation and compliance, one that is expected to have far-reaching implications for the consumer financial services industry.

A Shift in CFPB Priorities

The withdrawal of guidance and advisory opinions is consistent with the existing priorities of the administration, which include reducing regulatory burden and the size and reach of the Bureau. The CFPB continues to pursue cases involving consumer reporting, online installment lending, mortgage lending, and debt collection, and has left in place certain guidance documents to provide ongoing clarity and guidance to the industry.

The Bureau has also announced significant policy and operational changes since the transition of leadership in February, including the dismissal of pending litigation and the withdrawal of guidance documents. This has been accompanied by a shift in priorities, with a focus on mortgages, consumer reporting, debt collection, and other high-priority areas.

Market Impact

• Industry participants who rely on guidance documents will need to update their compliance practices and procedures to reflect the new landscape
• The withdrawal of guidance documents may cast uncertainty on certain areas of compliance, including Earned Wage Access programs

The withdrawal of 67 guidance documents has significant implications for the consumer financial services industry. Industry participants will need to update their compliance practices and procedures to reflect the new landscape, and the withdrawal of guidance documents may cast uncertainty on certain areas of compliance, including Earned Wage Access programs.

Background

The CFPB has relied on compliance bulletins, advisory opinions, interpretive rules, and circulars to provide its views regarding priorities and interpretations of federal consumer financial laws since its inception. Since the transition of leadership in February, the Bureau has announced significant policy and operational changes, including the dismissal of pending litigation and the withdrawal of guidance documents.

The largest single revocation by CFPB Acting Director Russell Vought occurred on May 12, 2025, with the withdrawal of eight policy statements, seven interpretive rules, 13 advisory opinions, and 39 other guidance documents.

Examples of Withdrawn Guidance

• The Bureau withdrew the 2024 circular titled Improper Overdraft Opt-in Practices, which imposed additional requirements on institutions’ record-keeping practices without going through formal notice-and-comment rulemaking
• The Bureau withdrew the December 2020 Advisory Opinion titled Truth in Lending (Regulation Z); Private Education Loans, which was drafted to respond to industry participants who expressed uncertainty regarding the application of Regulation Z to private refinancings of federal student loans

The withdrawal of guidance documents has significant implications for the consumer financial services industry. Industry participants will need to update their compliance practices and procedures to reflect the new landscape.

Remaining Actions and Stated Priorities

The CFPB continues to actively litigate certain cases and has provided a general outline of its priorities going forward. The cases still being litigated involve consumer reporting, online installment loans, mortgage lending, student lending, and debt collection. The Bureau has also announced significant policy and operational changes, including the dismissal of pending litigation and the withdrawal of guidance documents.

The new leadership has expressed a focus on mortgages, consumer reporting, debt collection, and other high-priority areas, and has shifted the priorities back to banks over nonbanks and to enlisting the states to conduct supervision and enforcement over nonbanks.

Key Takeaways for the Consumer Financial Services Market

• Continued focus on the mortgage, consumer reporting, and collection markets will be important for banks and nonbanks alike
• The withdrawal of guidance documents may cast uncertainty on certain areas of compliance, including Earned Wage Access programs

The withdrawal of guidance documents has significant implications for the consumer financial services industry. Industry participants will need to update their compliance practices and procedures to reflect the new landscape.

Market Impact

• Industry participants who rely on guidance documents will need to update their compliance practices and procedures to reflect the new landscape
• The withdrawal of guidance documents may cast uncertainty on certain areas of compliance, including Earned Wage Access programs

The withdrawal of 67 guidance documents has significant implications for the consumer financial services industry. Industry participants will need to update their compliance practices and procedures to reflect the new landscape, and the withdrawal of guidance documents may cast uncertainty on certain areas of compliance, including Earned Wage Access programs.

Industry Participants

• Industry participants will need to update their compliance practices and procedures to reflect the new landscape
• The withdrawal of guidance documents may cast uncertainty on certain areas of compliance, including Earned Wage Access programs

The withdrawal of guidance documents has significant implications for the consumer financial services industry. Industry participants will need to update their compliance practices and procedures to reflect the new landscape.

Remainder of the Withdrawn Guidance

The withdrawal of 67 guidance documents has significant implications for the consumer financial services industry. Industry participants will need to update their compliance practices and procedures to reflect the new landscape.

Conclusion

The withdrawal of guidance documents by the CFPB is a significant shift in the Bureau’s approach to regulation and compliance. The move is consistent with the existing priorities of the administration, which include reducing regulatory burden and the size and reach of the Bureau. The CFPB continues to pursue cases involving consumer reporting, online installment lending, mortgage lending, and debt collection, and has left in place certain guidance documents to provide ongoing clarity and guidance to the industry.

The withdrawal of guidance documents may cast uncertainty on certain areas of compliance, including Earned Wage Access programs. Industry participants will need to update their compliance practices and procedures to reflect the new landscape, and the CFPB’s ongoing priorities will shape the future of regulation and compliance in the consumer financial services industry.

The Consumer Financial Protection Bureau (CFPB) announced the revocation of nearly 70 interpretive rules, advisory opinions, and guidance documents in a sweeping move on May 12, 2025. The Federal Register Notice brings to an end an era of CFPB guidance that has been criticized for its overbreadth and lack of clarity. The move marks a significant shift in the CFPB’s approach to regulation and compliance, one that is expected to have far-reaching implications for the consumer financial services industry. This new development reflects a change in the CFPB’s approach under the new administration, which is prioritizing regulatory relief and reducing the Bureau’s scope and reach. As part of this effort, the CFPB has announced a range of policy and operational changes, including the dismissal of pending litigation and the withdrawal of guidance documents. The withdrawal of 67 guidance documents includes policy statements, interpretive rules, advisory opinions, and other guidance documents. Some of the withdrawn guidance documents have been criticized for their overbreadth, and their withdrawal may cast uncertainty on certain areas of compliance. Industry participants who rely on guidance documents will need to update their compliance practices and procedures to reflect the new landscape. The CFPB’s decision to withdraw these guidance documents is consistent with the existing priorities of the administration, which include reducing regulatory burden and the size and reach of the Bureau. The CFPB continues to pursue cases involving consumer reporting, online installment lending, mortgage lending, student lending, and debt collection, and has left in place certain guidance documents to provide ongoing clarity and guidance to the industry. Industry participants will need to adapt to the new landscape and ensure that their compliance practices and procedures are aligned with the CFPB’s revised priorities. The withdrawal of guidance documents may also have implications for the enforcement actions and supervisory designations of nonbank entities, which will require further attention. The CFPB’s approach to regulation and compliance will continue to evolve under the new administration, and industry participants will need to stay vigilant to ensure compliance with changing regulations and laws. The CFPB’s decision to withdraw guidance documents is a significant shift in the Bureau’s approach, and it is likely to have far-reaching implications for the consumer financial services industry. The CFPB’s action reflects a broader trend towards regulatory relief and reduced oversight in the consumer financial services industry. The Bureau’s decision to withdraw guidance documents is part of a larger effort to reduce the regulatory burden on industry participants and to promote greater efficiency and innovation in the financial services sector. The CFPB’s approach to regulation and compliance will continue to shape the future of the consumer financial services industry, and industry participants will need to adapt to the changing landscape. The withdrawal of guidance documents is a significant development that will require industry participants to update their compliance practices and procedures to reflect the new landscape. Some examples of withdrawn guidance documents include the Improper Overdraft Opt-in Practices circular, which imposed additional requirements on institutions’ record-keeping practices, and the December 2020 Advisory Opinion titled Truth in Lending (Regulation Z); Private Education Loans, which provided guidance on the application of Regulation Z to private refinancings of federal student loans. The CFPB’s decision to withdraw these guidance documents is consistent with the existing priorities of the administration, which include reducing regulatory burden and the size and reach of the Bureau. The CFPB continues to pursue cases involving consumer reporting, online installment lending, mortgage lending, student lending, and debt collection, and has left in place certain guidance documents to provide ongoing clarity and guidance to the industry. The withdrawal of guidance documents may cast uncertainty on certain areas of compliance, including Earned Wage Access programs. Industry participants who rely on guidance documents will need to update their compliance practices and procedures to reflect the new landscape. The CFPB’s ongoing priorities will shape the future of regulation and compliance in the consumer financial services industry. The CFPB’s decision to withdraw guidance documents is a significant shift in the Bureau’s approach, and it is likely to have far-reaching implications for the consumer financial services industry. The withdrawal of 67 guidance documents reflects a broader trend towards regulatory relief and reduced oversight in the consumer financial services industry. The CFPB’s approach to regulation and compliance will continue to shape the future of the consumer financial services industry, and industry participants will need to adapt to the changing landscape. The withdrawal of guidance documents is a significant development that will require industry participants to update their compliance practices and procedures to reflect the new landscape. The CFPB’s decision to withdraw guidance documents is consistent with the existing priorities of the administration, which include reducing regulatory burden and the size and reach of the Bureau. The CFPB continues to pursue cases involving consumer reporting, online installment lending, mortgage lending, student lending, and debt collection, and has left in place certain guidance documents to provide ongoing clarity and guidance to the industry. The withdrawal of guidance documents may cast uncertainty on certain areas of compliance, including Earned Wage Access programs. Industry participants who rely on guidance documents will need to update their compliance practices and procedures to reflect the new landscape. The CFPB’s approach to regulation and compliance will continue to evolve under the new administration, and industry participants will need to stay vigilant to ensure compliance with changing regulations and laws. The CFPB’s decision to withdraw guidance documents is a significant shift in the Bureau’s approach, and it is likely to have far-reaching implications for the consumer financial services industry. The CFPB’s action reflects a broader trend towards regulatory relief and reduced oversight in the consumer financial services industry. The Bureau’s decision to withdraw guidance documents is part of a larger effort to reduce the regulatory burden on industry participants and to promote greater efficiency and innovation in the financial services sector. The CFPB’s approach to regulation and compliance will continue to shape the future of the consumer financial services industry, and industry participants will need to adapt to the changing landscape. The withdrawal of guidance documents is a significant development that will require industry participants to update their compliance practices and procedures to reflect the new landscape. The CFPB’s decision to withdraw guidance documents is consistent with the existing priorities of the administration, which include reducing regulatory burden and the size and reach of the Bureau. The CFPB continues to pursue cases involving consumer reporting, online installment lending, mortgage lending, student lending, and debt collection, and has left in place certain guidance documents to provide ongoing clarity and guidance to the industry. The CFPB’s action reflects a broader trend towards regulatory relief and reduced oversight in the consumer financial services industry. The Bureau’s decision to withdraw guidance documents is part of a larger effort to reduce the regulatory burden on industry participants and to promote greater efficiency and innovation in the financial services sector. The CFPB’s approach to regulation and compliance will continue to shape the future of the consumer financial services industry, and industry participants will need to adapt to the changing landscape. The withdrawal of guidance documents is a significant development that will require industry participants to update their compliance practices and procedures to reflect the new landscape. The CFPB’s decision to withdraw guidance documents is consistent with the existing priorities of the administration, which include reducing regulatory burden and the size and reach of the Bureau. The CFPB continues to pursue cases involving consumer reporting, online installment lending, mortgage lending, student lending, and debt collection, and has left in place certain guidance documents to provide ongoing clarity and guidance to the industry. The withdrawal of 67 guidance documents has significant implications for the consumer financial services industry. Industry participants who rely on guidance documents will need to update their compliance practices and procedures to reflect the new landscape. The CFPB’s ongoing priorities will shape the future of regulation and compliance in the consumer financial services industry. The CFPB’s action reflects a broader trend towards regulatory relief and reduced oversight in the consumer financial services industry. The Bureau’s decision to withdraw guidance documents is part of a larger effort to reduce the regulatory burden on industry participants and to promote greater efficiency and innovation in the financial services sector.