Letter to the CFPB on the Draft Strategic Plan for FY 2026-2030

Dear Acting Director Vought:

The American Bankers Association (ABA) appreciates the opportunity to comment on the Consumer Financial Protection Bureau’s draft Strategic Plan for FY 2026–2030 (Strategic Plan). ABA strongly supports the CFPB's focus on reducing unnecessary regulatory burdens through transparent rulemaking, acting within clear statutory authority, improving the consumer complaint database, and prioritizing consumer fraud and scam education. ABA also supports the CFPB's commitment to refocus supervision on redressing quantifiable consumer harm and avoiding duplicative supervision, while urging the CFPB to maintain robust federal supervision of nondepository financial service providers to avoid gaps in consumer protection supervision. Finally, we recommend the CFPB implement the recent Executive Order: Promoting Access to Mortgage Credit.

The CFPB’s focus on reversing regulatory overreach and reducing unnecessary regulatory burdens will help make financial services more affordable and accessible for consumers. Higher compliance costs increase the cost of providing consumer banking services, which ultimately makes it more difficult for many Americans to access those services. Removing needless burdens will let banks serve more consumers and redirect resources towards banking activities that support economic growth and opportunity.

For these reasons, ABA strongly supports the Strategic Plan’s deregulatory objectives, including reviewing existing regulations and addressing regulatory burdens through rulemaking where appropriate. Rulemaking, informed by public comment and cost-benefit analysis, is more effective at creating sound policy and durable reforms than guidance or other subregulatory action. We welcome the CFPB’s plan to obtain meaningful feedback on existing regulations and to evaluate empirically the effects of proposed rules.

Download the comment letter to read the full text.