CFPB To Slash Bank Examinations And Switch To All-Virtual Reviews

The CFPB is planning to restart supervision in 2026 but with far fewer, shorter, and almost entirely virtual examinations of banks, fintechs, and other supervised entities.

What is changing

• The Bureau is expected to conduct fewer than 70 examinations annually, a sharp cut from historical levels (hundreds per year under prior leadership).​

• Exams will be conducted through all‑virtual reviews, built around document production, data sharing, and video/phone meetings rather than onsite visits.

• Examinations will be more tightly scoped, with shorter timelines than the prior roughly eight‑week standard, and focused on “priority markets” and clear statutory authority.

• Examiners are being instructed to rely more on institutions’ own independent testing where satisfactory, instead of duplicating work with full-scope transaction testing.​

New “humility” and supervision posture

• Starting with the 2026 cycle, examiners must open reviews by reading a “Humility in Supervisions Pledge,” emphasizing collaboration, transparency, and staying within statutory limits.

• Matters Requiring Attention will center on pattern‑and‑practice violations that cause tangible, identifiable consumer harm or clear disclosure problems, not marginal or technical issues.

• The Bureau is committing, on paper, to resolve more issues within supervision rather than escalating to enforcement, and to provide quicker responses on open exams and MRAs.

Scope and priorities

• Overall supervision “events” (exams, targeted reviews, etc.) are to be reduced by about 50% compared with prior years.​

• Focus will shift back toward depository institutions, with nonbanks more targeted to markets where Congress has clearly authorized federal oversight or where new rules (like for large digital wallets) apply.

• The CFPB says its top supervision priorities will be actual fraud with identifiable victims, redress for service members and veterans, and avoiding duplication where state or other federal regulators are active.

Why the cutback is happening

• The move comes after a roughly 10‑month pause in CFPB exams and continuing funding and staffing uncertainty, including public discussion in 2025 about potentially closing or radically shrinking the Bureau.

• Resource constraints are explicitly cited as a challenge to sustaining any robust exam program, which is one reason the agency is narrowing its focus and leaning on virtual processes and existing testing.

Practical implications for institutions

• Fewer but more targeted exams mean entities that remain in the CFPB’s sights (e.g., larger banks, major digital payment providers) may still see intensive scrutiny in specific risk areas, even if overall contact is reduced.

• Institutions should expect: earlier notice of exams, narrower document requests tied to stated scopes, greater ability to negotiate supplemental requests, and shorter onsite‑equivalent disruption because reviews stay virtual.

• A strong internal compliance testing program, clear documentation of consumer‑harm analysis, and readiness to self‑report issues will carry more weight in this new, largely remote supervision model.

Public CFPB documents and related commentary describe a focus on “identified priority markets” in 2026, but they do not yet publish a closed, named list of those markets.

What “priority markets” means

• The 2026 supervision cycle will concentrate resources on markets that present “pressing threats to consumers,” with explicit emphasis on service members, their families, and veterans.

• Exams will be limited to areas “clearly within the Bureau’s statutory authority” and will avoid duplicating oversight where states or other federal regulators already supervise the same products.

• Findings and MRAs will target pattern‑and‑practice violations causing tangible, identifiable consumer harm or clear disclosure violations in those markets, rather than technical issues across the entire institution.

Implications for 2026 targeting

• In practice, this means CFPB examinations are expected to prioritize larger or higher‑risk segments (for example, big depository institutions and markets with recurring consumer‑harm patterns), while de‑emphasizing low‑risk or heavily supervised areas, but the agency has not formally enumerated all covered product lines in public guidance yet.

• The Bureau has also signaled it may lean more on other regulators’ work where they already oversee a market, implying that CFPB “priority markets” will likely be those without strong alternative supervision or with recent evidence of significant harm.