CRL submitted comments to Acting Director Vought arguing the draft Strategic Plan retreats from the Bureau's statutory obligations at a moment of acute consumer affordability pressure, raising 3 core concerns:
- Fair banking is defined too narrowly. Objective 1.1 centers almost entirely on ideological debanking under EO 14331, with no mention of ECOA, fair lending, or the racial wealth gap. Objective 1.4's "unconstitutional racial classification" language signals a possible retreat from disparate impact theory—the primary tool for detecting discriminatory lending.
- Deprioritizing non-depository supervision undermines the plan's own risk-based goals. CRL reiterates its 2022 petition for a larger participant rule on personal loans, citing market scale, rapid BNPL and subprime growth, fintech APRs reaching 450–699%, and rent-a-bank evasion structures. The rule should cover both origination and servicing.
- Complaint database changes need transparency. Removing "improper submissions" without public, narrowly drawn criteria risks silencing consumers and eliminating a critical supervisory and research tool.
- Funding flag. The reduced Federal Reserve transfer request is inadequate to execute even the plan's limited activity.