CFPB adopts ‘Humility Pledge’ for examinations, says 2026 examination cycle is ‘fundamentally different’ from prior ones

Editor's Note: This article was originally published on Orrick's InfoBytes Blog and is republished here with permission. 
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On November 21, the CFPB’s Supervision Division announced changes to its supervision examination process, introducing a new “Humility Pledge” to be read by examiners at the start of each exam. The Bureau stated the pledge will be intended to promote greater transparency, professionalism and efficiency in supervisory exams, and will mark a shift away from prior practices.

The pledge stated that, beginning with the 2026 examination cycle, the Bureau will focus its supervision resources on pressing threats to consumers — particularly servicemembers, their families, and veterans — and on areas “clearly within” the CFPB’s statutory authority. The Bureau stated it will seek to avoid duplicative supervision where state regulators are already active and will provide advance notice of scheduled exams to allow entities to plan accordingly.

Under the new process, requests for information during exams will be limited to Bureau priorities and the defined scope of the exam, with follow-up requests discussed with the entity and tailored to the scope and information already provided. The pledge noted that examination findings and matters requiring attention (MRAs) will focus on “pattern and practice violations of law” where there is “substantive and identifiable” consumer harm, and that MRAs will be issued only for substantive violations or clear disclosure failures. The Bureau also indicated a reduction in examination times, and that examiners will be encouraged to complete work promptly and under budget.

The CFPB stated its goal is to work collaboratively with supervised entities to review compliance processes and address problems, encouraging self-reporting and resolving issues through supervision rather than enforcement when possible.