April 17, 2026
Acting Director Russell Vought
Consumer Financial Protection Bureau
1700 G Street, N.W.
Washington, DC 20552
By email submission: CFPB_Strategy@cfpb.gov
Re: NCRC Comment on Draft CFPB Strategic Plan for FY 2026-2030
Dear Acting Director Vought:
The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on the Consumer Financial Protection Bureau (CFPB) Draft Strategic Plan for FY 2026-2030 (Draft Strategic Plan).[1] Overall, the Draft Strategic Plan outlines a contraction of the CFPB’s mission, vision, and values that potentially will harm low-to-moderate income (LMI) communities.
NCRC is a network of more than 700 community-based organizations dedicated to creating a nation that not only promises but delivers opportunities for all Americans to build wealth and attain a high quality of life. We work with community leaders and policymakers to advance solutions and build the will to solve America’s persistent racial and socio-economic wealth, income, and opportunity divides, and to make a Just Economy a national priority and a local reality.
NCRC believes that the CFPB’s proposed goals, strategies and objectives[2] as described in the Draft Strategic Plan are inconsistent with the Consumer Financial Protection Act (CFPA), the CFPB’s authorizing statute, and the CFPB’s purpose. NCRC urges the CFPB to not: undercut its ability to protect consumers through dramatic staff reductions; scale back HMDA and Section 1071 regulations; place limits on its fair lending and other enforcement work; and limit its supervisory work to depository institutions.
If implemented as proposed, the proposed reductions in staff, the undoing of regulations that protect consumers from harm and discrimination, and the unreasonable limits on fair lending and enforcement work, will impede the CFPB from its statutory mandate to protect consumers. By focusing its supervisory work on depository institutions, it will leave vast portions of the consumer financial market unsupervised. These outcomes are inconsistent with a robust consumer protection program and NCRC urges the CFPB to address these concerns.
- CFPB should not undercut its ability to protect consumers by severely reducing its staff.
To execute on the Draft Strategic Plan’s third goal, the CFPB proposes to “strengthen” its “governance and culture” by what it calls a streamlining of organizational structures and functions.[3] Since the release of the Draft Strategic Plan, the CFPB filed a Reduction in Force (RIF) proposal with the Court of Appeals in connection with the lawsuit filed by the National Treasury Employees Union and others to prevent Acting Director from dismantling the CFPB through drastic reductions in staff.[4]
Stated simply, the CFPB’s most valuable resource is its staff. Traditionally, its staffing costs comprise the vast majority of its budget because without sufficient qualified staff, it cannot effectively supervise or enforce the law or otherwise execute its responsibilities under the CFPA. Despite this, in its RIF proposal, the CFPB seeks to cut its staff in half based on current staffing levels, leaving a skeletal crew to cover its entire jurisdictional supervisory and enforcement footprint. That means 50 employees to enforce and 77 employees to supervise a myriad of Federal consumer financial laws in connection the entire regulatory waterfront – including the consumer product lines offered or provided by depository institutions with over $10 Billion in assets and many nonbanks. While described as a means of increasing efficiency, the Draft Strategic Plan and the proposed RIF Plan will hamstring the CFPB’s ability to enforce or supervise compliance with Federal consumer financial laws, embolden bad actors to exploit its lack of resources, and allow consumer harms to flourish and remain unaddressed.
- CFPB should not scale back HMDA and Section 1071 Implementing Regulations
The Draft Strategic Plan proposes to implement a deregulatory agenda by rolling back regulations that the CFPB identifies as outdated, unnecessary, or unduly burdensome.[5] NCRC is concerned that in executing this goal the CFPB may remove or curb regulations implementing laws that are of critical importance to our fair lending work and LMI communities, including the Home Mortgage Disclosure Act (HMDA)[6] and Section 1071 of the Consumer Financial Protection Act.[7]
The CFPB should not weaken HMDA data collection. HMDA has long been one of the Bureau’s most important transparency and fair lending tools because it allows regulators, researchers, advocates, and communities to identify patterns in mortgage access, pricing, and potential discrimination. Comprehensive HMDA data allows NCRC to compare access to mortgage credit within neighborhoods and surrounding cities, produce local overviews of mortgage lending, and help design programs for low-income homebuyers based on actual market conditions.[8] Weakening HMDA would do more than reduce reporting obligations; it would diminish accountability and make it harder to identify unmet credit needs and fair lending concerns
Similarly, the CFPB should not reduce the scope of the data collected and maintained under Section 1071 of the Consumer Financial Protection Act. Congress required Section 1071 data collection “to facilitate enforcement of fair lending laws”[9] and to enable communities, governmental entities, and creditors to identify “business and community development needs and opportunities” for women-owned, minority-owned, and small businesses.[10] NCRC has consistently argued in both comments[11] and litigation[12] that Section 1071 was intended to do for small business lending what HMDA has long done for the mortgage market: provide a robust public dataset that can reveal disparities in access to credit, identify credit deserts, and inform community development strategies. A diminished Section 1071 rule would frustrate those statutory purposes and leave the public with an incomplete and unreliable picture of the small business lending market.
A meaningful Section 1071 database must be sufficiently comprehensive to show whether similar businesses are treated differently by race, ethnicity, or gender; whether underserved urban, suburban, and rural communities are receiving access to credit; and whether credit is being offered on fair and affordable terms rather than through higher-cost or predatory products.
The CFPB is tasked with protecting consumers from unfair, deceptive, and abusive acts and practices and from discrimination.[13] Data collection pursuant to HMDA and Section 1071 helps protect consumers from discrimination and thus robust regulatory reporting obligations must continue.
- CFPB should not place limits on its fair lending and other enforcement work
The Draft Strategic Plan proposed strategies within its goal of addressing pressing threats to consumers through enforcement action that are inaccurate, inconsistent with existing law, and inadequate to address consumer harm. For example, one of the strategies is to enforce fair lending laws without engaging in “unconstitutional racial classification or discrimination.”[14] However, in order to address potential lending discrimination based on protected characteristics, the Equal Credit Opportunity Act (ECOA) and related case law allow for the consideration of those protected characteristics, such as race, in the evaluation of the conduct.[15] This is particularly important when evaluating whether conduct has caused a disparate impact on communities that have been subject to systemic discrimination. And doing so is not “unconstitutional.”[16] Although the CFPB has proposed changes to Regulation B, ECOA’s implementing regulation, to prohibit disparate impact claims,[17] ECOA and its jurisprudence remain unchanged regardless of whether the CFPB finalizes changes to Regulation B. Thus, the CFPB’s proposed strategy regarding fair lending is inconsistent with current law.
Another strategy under this objective seeks to limit the expenditure of enforcement resources to matters that involve actual consumer harm with identifiable victims with material and measurable consumer damages.[18] Among other things, this could unreasonably limit the CFPB’s enforcement of disclosure regimes in statutes and their implementing regulations, such as the Truth in Lending Act[19] and Regulation Z.[20] With respect to TILA, Congress determined that the failure by creditors to provide required disclosures injures consumers,[21] but did not require proof of such harms to establish a violation. Instead, it imposes statutory damages for violations.[22] Similarly, the Military Lending Act and its implementing regulation[23] require lenders to provide certain disclosures to servicemembers and their dependents prior to providing credit and imposes statutory damages for violations. Requiring a showing of measurable injury could undercut the CFPB’s ability to address conduct that violates important laws that protect consumers, including servicemembers.
Imposing these proposed limitations on enforcement’s work unreasonably and unwarrantedly will impede the CFPB’s ability to protect consumers from fair lending discrimination and other conduct that violates Federal consumer financial protection laws.
- CFPB should focus supervisory resources on risks to consumers, regardless of the provider’s business structure.
The Draft Strategic Plan’s proposed strategies within its goal of addressing pressing threats to consumers through supervisory action are inconsistent. One of the strategies proposes to “[f]ocus supervision resources on institutions and their product lines that pose the greatest risk to consumers based on the nature of the product, field market intelligence, and the size of the institution and product line.” While another proposes to “shift the focus on supervisory action to depository institutions, opposed to non-depository institutions.”[24]
The CFPB commenced its nondepository supervisory program in 2012 with the express purpose of ensuring that nonbanks play by the same rules as banks.[25] The CFPB has authority to supervise nonbanks such as mortgage loan companies, payday lenders, and private education lenders, regardless of their size.[26] It also has the authority to supervise nonbank larger participants of other markets, as defined by rules issued by the CFPB.[27]
In some markets, depository institutions may not offer the products or services that pose the most risk to consumers. Or, if they do, they are not the biggest market players. For example, ten percent of 2024 CFPB complaints pertained to mortgages.[28] But, banks only originate approximately a third of all residential mortgages and own slightly less than half the servicing rights.[29] Prioritizing depository institutions for mortgage-related supervisory examinations will not address potential consumer risks in over half of the market. Part of the CFPB’s mandate is to monitor the mortgage lending market to prevent another mortgage crisis and thus it should focus its resources on markets and market-players according to the risks they pose to consumers, regardless of the entity’s business structure.
Other federal regulators do not have the ability to supervise nonbanks for compliance with consumer financial laws. A true level playing field requires the CFPB to focus its resources on remedying and preventing consumer harm, regardless of the market or type of institution. And when evaluating the size of an entity’s institutional product line, it should consider its size as relative to those of other market players.
The Draft Strategic Plan’s describes the CFPB’s mission as promoting “compliance with federal consumer financial laws.” Promoting compliance requires incentives for the market to comply with the law– namely, a robust supervisory and enforcement program that holds companies that violate the law accountable. The Draft Strategic Plan offers the opposite — severe reductions in staff, the undoing of regulations that protect consumers from harm and discrimination, unreasonable limits on fair lending and enforcement work, and vast portions of the consumer financial market left unsupervised. We urge the CFPB to revise its strategic plan to ensure it can engage in robust supervision, enforcement, and regulation that will protect consumers.
Thank you for the opportunity to offer our input on the CFPB’s Draft Strategic Plan for FY 2026-2030. If you have any questions, please contact me at jvantol@ncrc.org.
Thank you for your consideration.
Sincerely,
Jesse Van Tol
President and CEO
NCRC
[1] Consumer Fin. Prot. Bureau, Consumer Financial Protection Bureau Draft Strategic Plan for FY 2026-2030 [hereinafter Draft Strategic Plan].
[2] Id. (The Draft Strategic Plan outlines three goals, and, within each goal, it sets forth objectives and within each objective, it outlines strategies. The purported goals are to: (1) address pressing threats to consumers; (2) reduce unwarranted regulatory burdens; and (3) strengthen our governance and culture.)
[3] Id. at 11.
[4] Appellees’ Mot. to Modify the Stay Pending Appeal, for a Limited Remand, and to Place the Appeal in Abeyance, Nat’l Treasury Emps. Union v. Consumer Fin. Prot. Bureau, No. 25-5091 (D.C Cir. Mar. 31, 2026), Att. A. Notably, in December, NCRC and others filed action in a different District Court against the CFPB seeking to require the Acting Director’s to request the funds necessary to operate the CFPB and conduct its statutory functions. NCRC prevailed and in March, the District Court ordered Acting Director Vought to request the funds. Order Granting Mot. for Summ. J., Rise Econ. v. Vought et al, No. 5:25-cv-10481-EJD (N.D. Cal. Mar. 13, 2026).
[5] Draft Strategic Plan at 10.
[6] Regulation C, 12 CFR Pt.1003 (implementing Home Mortgage Disclosure Act,12 U.S.C. § 2801-2810).
[7] 15 U.S.C. § 1691c–2.
[8] See NCRC, Comment Supporting Maintaining Mortgage Data Collection under HMDA (Mar. 30, 2026), https://ncrc.org/ncrc-supports-maintaining-mortgage-data-collection-under-hmda/.
[9] Id. § 1691c–2(a).
[10] Id.
[11] See NCRC, Comment on the Proposed Rule to Strip Section 1071 Data Collection (Dec. 12, 2025), https://ncrc.org/ncrcs-comment-on -the-cfpbs-proposed-rule-to-strip-section -1071-data-collection/.
[12] Complaint ¶¶ 87–90, Rise Econ. Inc. v. Vought, No. 1:25-cv-02374 (D.D.C. July 23, 2025) (alleging that NCRC has consistently pressed CFPB to implement Section 1071, that Section 1071 was modeled after HMDA, and that the absence of Section 1071 data prevents NCRC from identifying discriminatory lending patterns and informing policy reform).
[13] 12 U.S.C. § 5511(b)(2).
[14] Draft Strategic Plan, at 9 (Objective 1.4).
[15] See Tex. Dep’t of Hous. and Cmty. Affairs v. Inclusive Cmtys. Project, Inc., 576 U.S. 519, 540 (2015), https://supreme.justia.com/cases/federal/us/576/519/ (holding disparate impact claims may be brought under the Fair Housing Act).
[16] Id. at 521. The Inclusive Communities majority considered and rejected the argument that disparate impact raises intentional discrimination or constitutional risks, noting that the doctrine “has always been properly limited in key respects to avoid” those issues.
[17] 90 Fed. Reg. 50,901, Nov. 13, 2025.
[18] Draft Strategic Plan at 9.
[19] 15 U.S.C. §§ 1601–1667f.
[20] Regulation Z, 12 CFR Pt. 1026.
[21] 15 U.S.C § 1602 (identifying in the findings and purpose section of TILA the harms of uniformed use of credit and unfair practices).
[22] 15 U.S.C. §1640(a) (Creditors who fail to comply with TILA “are liable” for statutory damages even absent proof of actual harm.)
[23] 10 U.S.C. § 987 (2024); 32 CFR Part 232.
[24] Draft Strategic Plan at 8.
[25] Steve Antonakes and Peggy Twohig, The CFPB Launces its Nonbank Supervision Program, Consumer Fin. Prot Bureau (Jan. 5, 2012), https://www.consumerfinance.gov/about-us/blog/the-cfpb-launches-its-nonbank-supervision-program/. This is consistent with the CFPA which provides that the CFPB enforces Federal consumer financial law “consistently, without regard to the status of a person as a depository institution, in order to promote fair competition[.]” 12 USC § 5511(b)(4).
[26] 12 U.S.C. § 5514(a)(1)(A).
[27] 12 U.S.C §§ 5514(a)(1)(B), 5514(a)(1)(2).
[28] Consumer Fin. Prot. Bureau, Consumer Response Annual Report January 1-December 31, 2024 (2025), cfpb_cr-annual-report_2025-05.pdf
[29] Fin. Stability Oversight Council, Report on Nonbank Mortgage Servicing 17 (2024).
