¶ Anti-CFPB Crusader
Rep. Blaine Luetkemeyer is a frequent opponent of the Consumer Financial Protection Bureau and its efforts to defend consumers. In 2017, Luetkemeyer cosponsored a Congressional Review Act resolution that successfully invalidated the Bureau’s arbitration rule meant to protect consumers’ right to class action lawsuits against bad financial actors. Luetkemeyer has also introduced and sponsored industry-supported legislation weakening the Bureau’s authority and effectiveness, including legislation forcing the Bureau and other regulators to prioritize corporate profits over consumer protections.
¶ Rep. Luetkemeyer Has Frequently Supported Anti-Consumer Efforts In Congress, Including Co-Sponsoring A Resolution That Successfully Invalidated The CFPB’s Arbitration Rule
¶ Rep. Luetkemeyer Vocally Opposed The CFPB’s Arbitration Rule—Which Made It Easier For Harmed Consumers To Join Together In Class-Action Lawsuits Against Abusive Financial Services Companies—And Co-Sponsored A Resolution That Eventually Invalidated The Rule.
The CFPB’s Arbitration Rule, Issued In July 2017, Made It “Easier For Consumers To File Or Join An Existing Group Lawsuit If They Are Harmed By A Financial Service Provider.” “Our new arbitration rule will make it easier for consumers to file or join an existing group lawsuit if they are harmed by a financial service provider, such as a bank or credit card company.” [Consumer Financial Protection Bureau, accessed 01/20/23]
- The CFPB Issued Its Final Rule On Arbitration Agreements On July 10, 2017. [Consumer Financial Protection Bureau, accessed 01/20/23]
The CFPB’s Arbitration Rule Prevented Financial Services Companies From “Inserting Agreements In Contracts That Prevent Customers From Filing Class-Action Lawsuits.” “The Republican-led House passed a resolution on Tuesday to block a Consumer Financial Protection Bureau (CFPB) rule that was published earlier this month; that rule prohibits financial service companies from inserting agreements in contracts that prevent customers from filing class-action lawsuits against a company. Those agreements, which have become popular in recent years, instead require consumers to settle complaints through arbitration, a less public and often less costly process favored by financial institutions.” [The Center for Public Integrity, 07/28/17]
July 2017: Rep. Luetkemeyer Issued A Statement Against The CFPB’s Arbitration Rule, Calling It An “‘Anti-Consumer Regulation’” That Would “‘Prompt More Lawsuits,’” Adding That The Rule Was Why The Bureau “‘Ultimately Needs To Be Substantially Reformed.’” “U.S. Rep. Blaine Luetkemeyer (MO-03) issued the following statement after the Consumer Financial Protection Bureau’s (CFPB) rule to prevent companies from using arbitration clauses: ‘This announcement is yet another anti-consumer regulation issued by the CFPB that will prompt more lawsuits all across the country,’ Luetkemeyer said. ‘The agency has published its own research which states arbitration has shown to be a positive tool for consumers. Yet, this week’s announcement is in complete contradiction to its reports. This action demonstrates why the CFPB ultimately needs to be substantially reformed.’” [Rep. Blaine Luetkemeyer, 07/11/17]
July 2017: Rep. Luetkemeyer Co-Sponsored H.J. Res. 111, A Resolution To Disapprove Of The CFPB’s Arbitration Rule. [Congress.gov, accessed 01/10/23]
- H.J. Res 111 Passed The House On July 25, 2017 And Became Law On November 1, 2017. [Congress.gov, accessed 01/20/23]
After H.J. Res. 111 Was Signed Into Law, The CFPB’s Arbitration Rule Was Invalidated. “On Nov. 1, 2017, the President signed a joint resolution passed by Congress disapproving the Arbitration Agreements Rule under the Congressional Review Act (CRA). Pursuant to the joint resolution, the Arbitration Agreements Rule has no force or effect. On Nov. 22, 2017, the Bureau published a notice removing the Arbitration Agreements Rule from the Code of Federal Regulations.” [Consumer Financial Protection Bureau, accessed 01/20/23]
The Leadership Conference On Civil And Human Rights Urged Congress To Reject H.J. Res. 111, Arguing That “Overturning The CFPB’s Rule Will Enable Big Banks, Payday Lenders, And Other Financial Companies To Force Victims Of Fraud, Discrimination, Or Other Unlawful Conduct Into A ‘Kangaroo Court’ Process.” “On behalf of The Leadership Conference on Civil and Human Rights, I urge you to oppose H.J. Res. 111, a resolution providing for Congressional disapproval of the Consumer Financial Protection Bureau’s final rule on forced arbitration clauses. Overturning the CFPB’s rule will enable big banks, payday lenders, and other financial companies to force victims of fraud, discrimination, or other unlawful conduct into a ‘kangaroo court’ process where their claims are decided by hired arbitration firms rather than by judges and juries – harming consumers and undermining civil rights and consumer protection laws.” [The Leadership Conference on Civil and Human Rights, 07/25/17]
¶ Rep. Luetkemeyer Has Taken Several Actions Against The CFPB And Other Federal Regulators, Including Introducing A Bill That Would Create A Commission-Style Of Leadership At The CFPB, And A Bill That Would Install An Inspector General, Which Received Support From Several Trade Groups Including The American Bankers Association, The Chamber And Consumer Bankers Association.
In July 2021, Rep. Luetkemeyer Introduced H.R. 4773, The "Consumer Financial Protection Commission Act," Which Would Restructure The CFPB Leadership By Creating A Commission And Eliminating The Single-Director Structure Of The CFPB.
July 2021: Luetkemeyer Introduced A Bill That Would Create A Bipartisan CFPB Commission And End What He Called The “Almost Limitless Power” Of Its Single Director. "Today, Congressman Blaine Luetkemeyer (R-MO), Ranking Member of the Subcommittee on Consumer Protection and Financial Institutions, introduced legislation to replace the position of the Director at the Consumer Financial Protection Bureau (CFPB) with a five-member bipartisan commission. This legislation has been cosigned by every Republican member of the House Financial Services Committee. ’The Bureau is constantly being used as a political football due to the almost limitless power of its director. Allowing one person to wield such unchecked authority over our economy is irresponsible and verges on negligence, which is precisely why many financial regulators are governed by a commission. The CFPB is currently being overseen by a single Acting Director who continues to make major, partisan policy decisions as he sees fit. The need for a bipartisan commission has never been clearer,’ said Congressman Luetkemeyer.” [Rep. Blaine Luetkemeyer, 07/28/21]
- Luetkemeyer Introduced H.R. 4773 "Consumer Financial Protection Commission Act. [Congress, accessed 11/22/22]
Luetkemeyer's Bill Received Praise From Several Financial Services Trade Groups—Including The National Association Of Federally-Insured Credit Unions (NAFCU), The Credit Union National Association (CUNA), The U.S. Chamber Of Commerce, The Consumer Bankers Association, And The American Bankers Association.
July 2021: The National Association Of Federally-Insured Credit Unions (NAFCU) Released A Statement In Support Of Luetkemeyer's Bill To Restructure The CFPB Saying: "NAFCU Has Long Advocated That The Bureau's Leadership Structure Should Be Reformed To A Commission-Based Model." "NAFCU has long advocated that the bureau's leadership structure should be reformed to a commission-based model, and has also offered support for bringing it under congressional appropriations oversight. Luetkemeyer previously introduced legislation to reform the CFPB's governance in March of 2020; NAFCU joined with 18 trade associations to voice support for the bill." [National Association of Federally-Insured Credit Unions, 07/29/21]
- PRESS RELEASE HEADLINE: Rep. Luetkemeyer reintroduces NAFCU-supported CFPB commission bill [National Association of Federally-Insured Credit Unions, 07/29/21]
July 2021: The Credit Union National Association (CUNA) Also Released A Statement In Support Of Luetkemeyer's Bill. "Rep. Blaine Luetkemeyer (R-Mo.) introduced a CUNA-supported bill Wednesday to replace the director of the Consumer Financial Protection Bureau (CFPB) with a bipartisan five-member commission. CUNA is a longtime supporter of a multi-member commission to lead the CFPB, especially in light of the U.S. Supreme Court decision that found the director is removable at will by the president." [Credit Union National Association, 07/28/21]
- PRESS RELEASE HEADLINE: Luetkemeyer introduces CUNA-backed CFPB commission bill [Credit Union National Association, 07/28/21]
July 2021: The Consumer Bankers Association Released A Statement In Support Of Luetkemeyer's Bill To Create A Commission At The CFPB, Saying "Thank You To Congressman Luetkemeyer For Reintroducing Legislation To Alter The Flawed Leadership Structure Of The CFPB, Which Holds Enormous Influence Over An Industry Affecting Millions Of Americans And Is Currently Led By An Unaccountable Sole Director." "CBA President and CEO Richard Hunt today issued the following statement after Congressman Blaine Luetkemeyer (R-MO), Ranking Member of the House Financial Services Subcommittee on Consumer Protection and Financial Institutions, introduced a bill to replace the position of the Director at the Consumer Financial Protection Bureau (CFPB) with a five-member bipartisan commission: ‘Thank you to Congressman Luetkemeyer for reintroducing legislation to alter the flawed leadership structure of the CFPB, which holds enormous influence over an industry affecting millions of Americans and is currently led by an unaccountable sole director.’" [Consumer Bankers Association, 07/28/21]
- The CBA Added: "’CBA Has Long Advocated For Replacing The Single Director With A Senate-Confirmed, Five-Person Commission To Lead The Bureau.’" "’Since its inception, revolving leadership at the CFPB has caused significant uncertainty for consumers and the market, as each new administration pursues their own regulatory priorities. CBA has long advocated for replacing the single director with a Senate-confirmed, five-person commission to lead the Bureau in a transparent manner.’" [Consumer Bankers Association, 07/28/21]
August 2021: The American Bankers Association, Along With Several Other Financial Trade Groups, Sent A Letter To Rep. Luetkemeyer Thanking Him For Introducing H.R. 4773 To Create A Bipartisan Commission Leadership Structure At The CFPB. "In a letter to Rep. Blaine Luetkemeyer (R-Mo.) today, ABA and several financial trade groups expressed support for H.R. 4773, the Consumer Financial Protection Commission Act, a bill that would transition the governance structure of the Consumer Financial Protection Bureau from having a sole director to a five-person, bipartisan commission. The bill is similar to bipartisan legislation introduced in previous Congresses and has long been supported by the financial services industry." [American Bankers Association Banking Journal, 08/18/21]
- Among Major Group Signees Were The Consumer Bankers Association, CUNA, The Mortgage Bankers Association, NAFCU, The National Association Of Realtors, The Small Business & Entrepreneurship Council, And The U.S. Chamber Of Commerce, Among Others. [Joint Trade Group Letter To Representative Blaine Luetkemeyer, 08/18/21]
Several Trade Groups Lobbied On H.R. 4773 In 2021, Including The American Bankers Association, The Consumer Bankers Association, The Independent Community Bankers Of America, The U.S. Chamber Of Commerce And ACA International:
| Trade Association | Lobbied On H.R. 4773 "Consumer Financial Protection Commission Act" | Money Spent In 2021 |
| American Bankers Association | Link | $10,283,000 |
| Consumer Bankers Association | Link | $3,430,000 |
| Independent Community Bankers of America | Link | $4,150,000 |
| U.S. Chamber of Commerce | Link | $66,410,000 |
| National Association of Realtors | Link | $44,004,025 |
| ACA International | Link | $736,000 |
|
TOTAL: $129,349,667 |
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In November 2021, Luetkemeyer Introduced H.R. 6038 The "CFPB—IG Reform Act Of 2021" To Establish An Inspector General At The Bureau, Which He Claimed Would “Minimize Politically Motivated Actions” At The CFPB.
November 2021: Luetkemeyer Introduced A Bill That Would Establish An Inspector General At The CFPB, Claiming It Would “Minimize Politically Motivated Actions” At The Bureau. "’The political nature of the CFPB continues to cause problems and the lack of a designated Inspector General to conduct proper oversight of the Bureau only exacerbates these problems. Establishing an independent Inspector General specifically for the CFPB would minimize politically motivated actions and drastically improve transparency at the Bureau,’ said Congressman Luetkemeyer.” [Rep. Blaine Luetkemeyer, 11/18/21]
- Luetkemeyer Introduced H.R. 6038 "CFPB—IG Reform Act Of 2021" [Congress, accessed 11/22/22]
November 2021: The National Association Of Federally-Insured Credit Unions Sent A Letter Thanking Luetkemeyer For Introducing The CFPB—IG Reform Act Of 2021, Writing, "NAFCU Supports Your Timely Legislation," And "Opposes The CFPB's Examination And Enforcement Authority Over Credit Unions, Given They Were Not Responsible For The Financial Crisis And As Non-Profit Cooperatives Are Focused On Serving Their Members, Not Making A Profit." "NAFCU supports your timely legislation to create an Office of the Inspector General at the CFPB. This new office will bring much-needed oversight and accountability to the CFPB. NAFCU opposes the CFPB’s examination and enforcement authority over credit unions, given they were not responsible for the financial crisis and as non-profit cooperatives are focused on serving their members, not making a profit." [NAFCU Letter To Representative Blaine Luetkemeyer, 11/19/21]
- The National Association Of Federally-Insured Credit Unions Lobbied In Support Of This Bill. [Opensecrets, accessed 11/22/22]
¶ 2017: Luetkemeyer Voted For H.R. 1009, The OIRA Insight, Reform, and Accountability Act, A Bill That Sought To Undermine The CFPB's Independence And "Would Have A Crippling Effect On The Regulation Of Our Financial System."
March 2017: Rep. Luetkemeyer Voted For H.R. 1009, The OIRA Insight, Reform, and Accountability Act. [Clerk of the U.S. House of Representatives, 03/01/17]
- H.R. 1009 Passed The House On March 1, 2017. [Congress.gov, accessed 01/10/23]
H.R. 1009 Threatened The CFPB's "Freedom As An Independent Agency To Enact Regulation." “The Consumer Financial Protection Bureau’s freedom as an independent agency to enact regulation could soon change due to a new bill working its way through Congress. […] The bureau wouldn’t be the only agency affected. Other independent agencies include: the Federal Reserve Board, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission and the National Credit Union Administration." [HousingWire, 03/10/17]
Consumer Advocates Argued H.R. 1009 "Would Render The Independence Of These Agencies Meaningless." "This bill would render the independence of these agencies meaningless, and make agencies critical to protecting consumers and holding Wall Street accountable, such as the Consumer Financial Protection Bureau, the Consumer Product Safety Commission, the Federal Communications Commission, and the Federal Trade Commission, independent in name only." [Public Citizen, 02/28/17]
Consumer Advocates Also Argued H.R. 1009 "Would Have A Crippling Effect On The Regulation Of Our Financial System." "This legislation would have a crippling effect on the regulation of our financial system. It would add an unnecessary, burdensome, and time-consuming layer of bureaucracy to the process of completing oversight rules for our largest financial institutions. It would give Wall Street lawyers numerous new tools to overturn agency actions in court, based on compliance with a lengthy, vague, and contradictory new set of analytic hurdles. Finally, it would violate the independence of financial regulatory agencies that are designed to be insulated from White House influence." [Americans for Financial Reform, 03/01/18]
¶ 2018: Luetkemeyer Voted For H.R. 1116, The Taking Account of Institutions with Low Operation Risk (TAILOR) Act of 2017, Which Would Have Forced The CFPB And Other Regulators To “Prioritize The Costs Of Regulations To Financial Institutions,” Among Other Anti-Consumer Provisions.
March 2018: Rep. Luetkemeyer Voted For H.R. 1116, The Taking Account of Institutions with Low Operation Risk (TAILOR) Act of 2017. [Clerk of the U.S. House of Representatives, 03/14/18]
- H.R. 1116 Passed The House On March 14, 2018. [Congress.gov, accessed 01/10/23]
Consumer Advocates Argued H.R. 1116 Would "Force Regulators To Prioritize The Costs Of Regulations To Financial Institutions." "This sweeping mandate would force regulators to prioritize the costs of regulations to financial institutions over the offsetting benefits to consumers and the general public. The mandate implies that regulators would be unable to act to protect the public if such action led to any significant costs to Wall Street banks." [Americans for Financial Reform, 03/12/18]
H.R. 1116 Was Criticized By House Democrats As Allowing Banks And Corporations New Ways To Challenge Consumer Protections Issued By The CFPB And Other Regulators. "If enacted, H.R. 1116 would undo these efforts by providing every financial institution overseen by agencies like the Federal Deposit Insurance Corporation (FDIC) or the Consumer Financial Protection Bureau with new opportunities to challenge rulemakings in court if they felt a regulation was not uniquely tailored to their individual firm." [House Financial Services Committee, 03/06/18]
H.R. 1116 Would Require Banking Regulators To Tailor Their Actions For Banks' "Specific Risk Profiles." "H.R. 1116 would require the federal banking regulators—the Federal Deposit Insurance Commission (FDIC), the Office of the Comptroller of the Currency (OCC), the National Credit Union Administration (NCUA), the Consumer Financial Protection Bureau (CFPB), and the Federal Reserve—to adapt their regulatory actions to the specific risk profiles and business models of financial institutions that are subject to regulation." [House Financial Services Committee, 12/12/17]
¶ Rep. Luetkemeyer Has Shown Approval For Several Court Rulings That Deemed The CFPB’s Funding And Leadership Structure Unconstitutional And Has Lent Support To Trade Groups That Have Sued The CFPB On The Grounds That It Has Stepped Beyond Its Authority In Interpreting Financial Institutions' Unfair, Deceptive, Or Abusive Acts And Practices (UDAAPs) Against Consumers.
Rep. Luetkemeyer Has Released Several Statements Regarding Court Rulings That The CFPB Funding And Leadership Structure Are Unconstitutional, And Has Also Gone After The CFPB For Its Crackdown On Junk Fees, Stating The Bureau Is "Doubling Down On Its Efforts To Expand The Administration's Reach Beyond It's Legal Boundaries."
June 2020: Luetkemeyer Released A Statement Praising A Supreme Court Ruling That Found The CFPB Director's Position Was Unconstitutional And Was Subject To Removal By The President. "Congressman Blaine Luetkemeyer (MO-03) released the following statement regarding the Supreme Court case, Seila Law v. Consumer Financial Protection Bureau, in which the Court ruled today that the current director’s position is unconstitutional and should be removable at the will of the president. ‘Today, the Supreme Court confirmed what many of us have been saying for years: the unchecked power of the CFPB director is unconstitutional. While the ruling is a step in the right direction, it does not change the fact that consumer protection regulation is controlled by a sole director, giving one person an enormous amount of power over the American economy. It also subjects the Bureau to partisan policy shifts with each new Administration.’" [Rep. Blaine Luetkemeyer, 06/29/20]
October 2022: Rep. Luetkemeyer Released A Statement Criticizing The CFPB And The Biden Administration's Crackdown On "Junk Fees," Citing A Fifth Circuit Court Decision Ruling That The Agency's Funding Was Unconstitutional. "’It is important to note that guidance is neither a law nor a rule. It is not enforceable and any attempt to do so would be a violation of the Bureau’s legal authority. However, just a week after the Federal Court ruled that the CFPB’s funding structure is unconstitutional, the White House is doubling down on its efforts to expand the Administration’s reach beyond its legal boundaries. CFPB Director Chopra coined the term ‘junk fees’ in an effort to regulate industries and products he knows do not fall within the Bureau’s jurisdiction. Despite the repeated use of their new favorite term, neither the White House nor the Bureau can provide a legal definition of the term or the statutory authority to pursue these actions,’ said Luetkemeyer.” [Rep. Blaine Luetkemeyer, 10/26/22]
- Rep. Luetkemeyer, Along With Then-Ranking Member McHenry Had Previously Sent A Letter To Director Chopra In March 2022 On 'Junk Fees,' Writing That "Overdraft Protection Is A Short-Term Liquidity Product That Can Aid Consumers In Making Ends Meet." "’Overdraft protection is a short-term liquidity product that can aid consumers in making ends meet when a deposit account balance is low, particularly for those consumers who are unable to qualify for traditional credit products. A recent study indicates most consumers are well aware of the cost associated with tapping into overdraft coverage and choose to use this low-cost option to cover temporary funding shortfalls. Some financial institutions will derive a higher percentage of revenue from deposit account-related fees, such as overdraft or NSF, based on their business models and product offerings. Moreover, in December 2021, Acting Comptroller Hsu outlined potential reforms while cautioning that ‘limiting overdrafts may limit the financial capacity for those who need it most.’” [Rep. Blaine Luetkemeyer, 03/31/22]
October 2022: Luetkemeyer Released A Statement Praising The Fifth District Court's Decision Ruling The CFPB Unconstitutional "Yesterday's ruling confirms what commonsense Americans have known all along: the CFPB’s funding structure is unconstitutional. The Appropriations Clause was put in place by our Founders to ensure the American people’s representatives have the proper oversight over federal funding. With this ruling, the Bureau will no longer be able to rely on their annual blank check from the Federal Reserve, but rather be subjected to the necessary Congressional supervision and level of transparency the American people expect from a government agency,’ said Luetkemeyer. [Rep. Blaine. Luetkemeyer, 10/20/22]
Rep. Luetkemeyer Has Long Criticized The CFPB Under The Biden Administration, Particularly On Its New Supervision Of Unfair, Deceptive, Or Abusive Acts And Practices (UDAAP), Even Lending Support To The U.S. Chamber Of Commerce's Lawsuit Against The CFPB Challenging Its Authority To Enforce Against These Anti-Consumer Practices.
March 2021: Luetkemeyer Released A Statement After The CFPB Rescinded A Policy Change By Former Director Kathy Kraninger, Accusing The Biden Administration Of "’Reverting To A Time When Consumer Protections And Sound Regulation Took A Backseat To Ideological Crusades.’" "’Director Kraninger’s policy statement gave the CFPB the tools it needed to cultivate compliance and protect consumers from abusive practices. By eliminating this statement, the Biden Administration appears to be reverting to a time when consumer protections and sound regulation took a backseat to ideological crusades. These actions make the Bureau less able to prevent consumer harm while fostering financial products that benefit consumers.’" [Rep. Blaine Luetkemeyer, 03/11/21]
February 2022: Rep. Luetkemeyer Criticized A CFPB Rule That Collects "The Race And Gender Information Of Small Business Owners" From Financial Institutions Saying It Is "Extremely Troubling And Goes Against Decades Of Anti-Discrimination Laws." "’Forcing financial institutions to collect the race and gender information of small business owners is extremely troubling and goes against decades of anti-discrimination laws. However, that is exactly what the CFPB is doing. Even worse, the Bureau refuses to tell us what information they will or will not make public, or even share how they plan to make that determination. Yet again, they are skirting the legal rulemaking process, this time threatening the privacy of small business owners across America,’ said Luetkemeyer, Hill and Williams.” [Rep. Blaine Luetkemeyer, 02/16/22]
March 2022: Luetkemeyer Sent A Letter To The CFPB Criticizing A Tweet And Subsequent Blog Post For "Demonizing Automobile Lenders And Servicers" Writing. "’The tweet and this blog post indicate a trend amongst auto lenders, servicers, and investors to prematurely repossess cars solely based on the increase in the price of the vehicle since the beginning of the pandemic. Moreover, your tweet equates the repossessing a vehicle when contractually obligated payments are not made with theft. That is a gross mischaracterization that blurs the line between legal actions and the spike in crime we are seeing in cities across the U.S.’" [Rep. Blaine Luetkemeyer, 03/11/22]
September 2022: Luetkemeyer Released A Statement Showing Support For A Chamber-Led Lawsuit Against The CFPB's UDAAP Policy Stating, "Today's Action From Non-Partisan Business And Banking Associations Is A Welcomed Statement That 'Enough Is Enough."' "As the Biden Administration’s agenda continues to lose the support of the American people and Congress, its radical regulators continue to exceed their legal boundaries. Director Chopra’s actions have made it clear he answers only to himself and his own whims – an extremely inappropriate way for a government official to operate. Today’s action from non-partisan business and banking associations is a welcomed statement that ‘enough is enough.’ The American people deserve a CFPB that operates with transparency and respects the rule of law, and it’s long past time the Administration be held accountable for doing neither,’ said Luetkemeyer.” [Rep. Blaine Luetkemeyer, 09/28/22]
- May 2022: Luetkemeyer Had Previously Sent A Letter To The CFPB Alongside Patrick McHenry Criticizing The CFPB Over Its New Interpretation Of UDAAP. "Today, Congressman Blaine Luetkemeyer (MO-03), top Republican on the Subcommittee on Consumer Protection and Financial Institutions, Congressman Patrick McHenry (NC-10), top Republican on the House Financial Services Committee, led a letter with House Financial Services Committee Republicans to Consumer Financial Protection Bureau (CFPB) Director Rohit Chopra regarding the CFPB’s new unfair, deceptive, or abusive acts and practices (UDAAPs) supervisory policy and the recent changes to CFPB administrative adjudication procedures that deviate significantly from past practices." [Rep. Blaine Luetkemeyer, 05/19/22]