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On September 22, 2025, the CFPB terminated two consent orders, one involving a national bank and the other involving a mortgage servicer. The orders were originally issued under prior administrations and alleged violations of the Home Mortgage Disclosure Act (HMDA), the Consumer Financial Protection Act (CFPA), the Real Estate Settlement Procedures Act (RESPA), and the Fair Credit Reporting Act (FCRA).
The Bureau terminated its October 2020 order against the bank after finding the institution had satisfied its obligations. That order had required a $200,000 civil money penalty and the implementation of a compliance-management system following the Bureau's findings of widespread errors in 2016–2017 HMDA data reporting. The CFPB alleged that the errors resulted from inadequate staffing, insufficient training, and ineffective oversight of mortgage-loan data.
The Bureau also terminated its January 2017 order against the mortgage servicer after determining the company had completed its obligations. That order had required $265,000 in consumer redress, implementation of a redress plan, and changes to business practices. The CFPB had alleged that the servicer improperly accepted referral fees in violation of RESPA and accessed consumer credit reports without a permissible purpose in violation of FCRA. With those financial and compliance obligations now satisfied, the Bureau formally closed the matter.
The Bureau's September 2025 orders waived any allegations of noncompliance and terminated all remaining obligations, formally closing both matters.
Putting It Into Practice: The termination of both orders reflect the Bureau's continued practice of winding down legacy enforcement actions once remedial obligations have been met (previously discussed here and here). Institutions should not view the closures as a softening of oversight, as both federal and state regulators have continued their supervision on banks and mortgage servicers (previously discussed here and here). Mortgage lenders and servicers should maintain strong compliance-management systems, board-level oversight, and documentation to withstand regulatory review, while monitoring state enforcement activity for ongoing developments.
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