In the absence of active enforcement by federal banking regulators, many financial institutions are choosing this moment to take a second look at their compliance policies and procedures. Recent administrative actions implicating access to financial services may particularly require financial institutions to reevaluate their Consumer Due Diligence (CDD) procedures and Consumer Identification Program (CIP).

Since taking office, the Trump administration has significantly curtailed the CFPB’s rulemaking and enforcement activity. Recently, Congress and federal courts have been grappling with what that means for CFPB employees and the rules the CFPB has enacted and enforces. On April 9, 2025, the United States House of Representatives voted to pass a joint resolution disapproving a CFPB rule that would make certain large payment companies subject to Regulations E and Z. The same day, the Court of Appeals for the D.C. Circuit heard oral arguments to resolve a TRO that would maintain the existence of the CFPB as it stood before the administration change. What does this mean for you and your clients?