CFPB’s Vought Defends Terminating Citi Consent Order

Here’s a full breakdown of where this story stands:

Background: The 2023 Consent Order

The original order, issued in November 2023, found that Citi engaged in a pattern of discrimination against Armenian American credit card applicants from 2015 through 2021 — specifically targeting applicants with surnames ending in “-ian” or “-yan,” particularly in the Glendale, California area. The CFPB’s original enforcement action required Citi to pay $1.4 million in consumer redress and a $24.5 million civil monetary penalty, with monitoring to continue until 2028.

The Early Termination

On October 16, 2025, Vought signed an order terminating the consent order — three years ahead of schedule — citing Citi’s completion of its penalty and redress obligations. The Bureau also waived any alleged noncompliance.

Congressional Pushback

Sen. Adam Schiff (D-CA) and fellow lawmakers sent a bicameral letter to Vought on April 23, 2026, demanding explanations and questioning whether CFPB still agreed with the 2023 discrimination finding.

Vought’s Defense (Today)

In his response reported May 14, 2026, Vought made several arguments:

• The affected population was small enough that “the impact was not even detectable in any statistical analysis”

• Of the 573 individuals sent redress checks, more than 100 were not actually Armenian — including people surnamed “Christian” or “Bryan”

• 126 of the 573 redress checks were never cashed; those funds were redistributed to the 447 who did cash them

• Total consumer redress paid: $1,370,207.16

• The $24.5 million civil penalty was “draconian” and “outsized” — 17 times the actual redress amount

• “There are no unfulfilled obligations as of the date of termination, and Citi committed to ongoing monitoring regardless of termination”

Key Tensions

The Schiff letter highlights a critical unresolved question: whether Vought’s CFPB still agrees that Citi’s discriminatory pattern lacked any legitimate, non-discriminatory justification — the original finding underpinning the entire action. Vought’s framing essentially recharacterizes the enforcement as overbroad, which has significant implications for how the current CFPB views ECOA pattern-or-practice cases going forward.

This fits squarely into the broader Trump-era CFPB rollback — the Consumer Federation of America has catalogued over 40 public enforcement actions dismissed or terminated since January 2025.