H.R. 10184: Consumer Financial Protection Accountability and Reform Act of 2026

This bill would substantially change how the Consumer Financial Protection Bureau (CFPB) operates and how it can regulate and enforce consumer finance laws. It would reduce the CFPB’s independent funding by moving it to the normal congressional appropriations process. It would also require more formal review of CFPB rules, including cost-benefit analysis, analysis of effects on small businesses, periodic review by the Office of Management and Budget, and the creation of an Inspector General for the agency.

CFPB enforcement and rulemaking changes

The bill would narrow the CFPB’s ability to use “abusive” conduct as a basis for enforcement and would require clearer definitions and notice before enforcement in many cases. It would define “substantial injury” as concrete, measurable consumer harm. It would also limit where the CFPB can bring certain UDAAP cases, what claims it can bring, and how far back it can reach in investigations and enforcement actions.

The bill would bar the CFPB from regulating attorneys’ litigation activities. It would also require the agency to include disclaimers when issuing guidance, making clear when guidance is not binding law. In addition, it would create safe-harbor rules for certain small-dollar credit products, require a study of buy now, pay later products, and add disclosure requirements for earned wage access products.

Earned wage access and related consumer protections

The bill would impose specific consumer protections on earned wage access providers. These would include:

• no debt collection lawsuits or arbitration for repayment disputes
• no reimbursement demands for overdrafts
• no fee-sharing with employers
• no penalties or negative credit reporting for nonpayment
• no default tipping requirements
• nondiscrimination requirements
• data privacy and protection rules
• compliance with state law limits where applicable

The bill would also tighten CFPB coordination of rulemaking, supervision, and enforcement in this area.

Agency structure, complaints, and data handling

The bill would require CFPB asset-size thresholds to be updated every five years based on GDP and adjusted for inflation, with the thresholds rounded by size. It would also change how the CFPB handles consumer complaints by requiring consumer attestation, screening for fraud and duplicate complaints, and stronger confidentiality protections.

For small business lending data, the bill would require notice-and-comment rulemaking before the CFPB can delete or change that data.

Relevant Companies

• DAVE — A provider of earned wage access and financial services; the bill’s disclosure, fee, collection, and data rules could directly affect its business practices.
• UPST — A consumer lending platform that could be affected by changes to CFPB rulemaking, enforcement standards, and safe-harbor treatment for small-dollar credit.
• LC — A consumer and small-business lending company that could be impacted by revised CFPB oversight, complaint handling, and lending data rules.
• SOFI — Offers consumer financial products and lending services that may be affected by CFPB supervision, enforcement limits, and small-dollar credit rules.
• LPRO — A consumer lending company whose products and compliance costs could be influenced by CFPB enforcement and rulemaking changes.
• AFRM — A buy now, pay later provider that could be affected by the required BNPL study and any resulting CFPB actions or disclosures.