The law is still the law, even though Consumer Watchdog CFPB has removed guidance documents

Legal experts warn companies that they can still be sued for violating CFPB regulations

By Truman Lewis of ConsumerAffairs

May 14, 2025

• The Consumer Financial Protection Bureau (CFPB) has withdrawn 67 guidance documents related to key consumer protection laws, but legal experts emphasize the laws themselves remain fully in effect.

• The National Consumer Law Center (NCLC) says companies must still follow existing regulations and that prior CFPB guidance retains legal relevance in litigation and court interpretation.

• The move may signal further rollbacks, including potential limits on public access to the CFPB complaint database, a vital tool for consumer advocates.

In a sweeping regulatory shift, the Consumer Financial Protection Bureau (CFPB) last week formally rescinded 67 guidance documents that have helped interpret major U.S. consumer protection laws for more than a decade. The decision, which affects laws related to credit reporting, lending, debt collection, and more, sparked concerns among consumer advocatesbut legal experts say protections for consumers remain intact.

The law is still the law, said Diane Thompson, deputy director and chief advocacy officer at the National Consumer Law Center (NCLC), in a news release.Companies must continue to follow the law or run the risk of private litigation, with or without guidance from the CFPB.

The NCLCs new analysis, Continued Vitality of 67 Withdrawn CFPB Guidance Documents, explains that the Bureaus withdrawal does not change the underlying statutes or regulations. Rather, the CFPB has simply chosen to no longer rely on these particular documents in its own enforcement actions.

Laws remain in effect

Critically, courts and consumer attorneys can still look to the withdrawn guidance for persuasive legal arguments, according to NCLC. The article organizes the rescinded materials by the laws they interpret, including:

• Fair Credit Reporting Act (13 documents)

• Fair Debt Collection Practices Act (6)

• Truth in Lending Act (10)

• Equal Credit Opportunity Act (8)

• Electronic Funds Transfer Act and others

The withdrawal also includes policy statements dating back to 2012, some of which explain the CFPBs rationale for providing public access to its complaint database. While the database remains active and searchable for now, its future is uncertain. NCLC cautions that if its removed, public access to consumer complaints could be limited to Freedom of Information Act requests or archived versions without advanced search features.

This move suggests the agency may be deprioritizing transparency and accountability at a time when consumers continue to face deceptive and abusive financial practices, said Thompson.

Still, NCLC assures consumer attorneys that the guidance remains valuable in court, and its substance continues to be cited in the Centers legal treatises and digital library resources.

#law #law #Consumer #Watchdog #CFPB #removed #guidance #documents