- within Cannabis & Hemp and Insolvency/Bankruptcy/Re-Structuring topic(s)
On November 21, the CFPB announced changes to how its Supervision Division will conduct examinations, including a new "Humility Pledge" that examiners must read to supervised entities at the start of each review. The Bureau stated that the updated approach reflects its commitment to operating within its statutory authority and aligns with the Memorandum on Supervision and Enforcement Priorities issued in April 2025 (previously discussed here).
The CFPB explained that exams next year will center on markets it has identified as priorities and on conduct that allegedly results in concrete consumer harm. As part of this revised approach, exam teams will provide earlier notice of upcoming reviews, outline expectations in advance, and narrow document requests to materials tied to the defined scope. Any supplemental inquiries, the Bureau said, will first be discussed with the entity to ensure they remain targeted and proportionate.
The agency also stated that the duration of exams will be shortened to reflect the refined scope and that examiners will be expected to complete their work efficiently. Matters Requiring Attention will focus on issues involving meaningful consumer impact or apparent disclosure problems. The Bureau added that supervised entities should see quicker responses on open examinations and MRAs, and that its intent is to resolve issues within the supervisory process when appropriate rather than escalating them to enforcement.
Putting It Into Practice: Uncertainty surrounding the CFPB's long-term role in consumer-financial oversight has intensified as the agency prepares to deplete its remaining funds and transition active litigation to the Department of Justice (previously discussed here and here). The introduction of the Humility Pledge reflects this shifting posture and signals that future exams may be narrower and focused on more core issues. Institutions subject to CFPB supervision should continue monitoring federal developments closely as the Bureau's operational direction evolves heading into 2026.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
