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Jonathan Kolodziej represents all types of consumer financial service providers in regulatory compliance, examination and enforcement matters. Through this work, he has assisted bank and non-bank mortgage servicers, mortgage originators, debt collectors, depository institutions, credit card issuers, small dollar lenders, reverse mortgage companies, investment firms, and various industry trade associations.

Russ Vought’s CFPB has been busier over the past two weeks, but not because of increased enforcement or supervision efforts. Instead, recent actions indicate that the administration intends to keep Vought in the acting director position so he can shutter or even more substantially shrink the CFPB and the laws it enforces. But the CFPB’s

On September 22, 2025, California Gov. Gavin Newsom signed the Mortgage Forbearance Act into law, with an immediate effective date. The law, designed to provide emergency relief to California mortgage loan borrowers impacted by the various wildfires that occurred earlier in 2025, is in many ways reminiscent of the CARES Act forbearance framework from 2020.

On September 8, 2025, the Office of the Comptroller of the Currency (OCC) released Bulletin 2025-22, announcing that the OCC will assess an entity’s debanking practices when considering licensing filings and applications and during Community Reinvestment Act (CRA) assessments. National banks and federal savings associations are now on notice that prior allegations of politicized

Late last year, we predicted that the Trump administration would bring federal action to target de-banking, and on August 7, 2025, President Trump signed a much-anticipated executive order to address the issue. Banks and credit unions should now expect to feel the impact early on in the form of horizontal reviews and inquiries from their

Within approximately 48 hours, starting on the evening of Friday, February 7, 2025, the trajectory of the Consumer Financial Protection Bureau (CFPB) was significantly altered. Among other things, a new acting director was installed, a more comprehensive internal pause – one that now explicitly covers supervision, examination, and enforcement activities – was put in place

On December 17, 2024, amid a flurry of activity by the Consumer Financial Protection Bureau (CFPB), the agency released an Issue Spotlight discussing “problems with mortgage companies” that homeowners face “after divorce or [the] death of a loved one.” The report relies on consumer complaints that have been submitted through the CFPB’s complaint portal to

On Thursday, November 21, 2024, the Consumer Financial Protection Bureau (CFPB) published a final rule that will soon provide it with supervisory authority over large companies in the general-use digital consumer payment applications market. This rule will become effective 30 days after it is published in the Federal Register and will subject large participants in