On July 18, 2025, the American Financial Services Association (AFSA) submitted a comment letter addressing the Consumer Financial Protection Bureau's (CFPB) proposal to alter the allocation of money collected from fines imposed on financial institutions. Previously, these funds were deposited into the Civil Penalty Fund and used either to compensate consumers or for consumer education and financial literacy programs. The CFPB now proposes that all money in the fund be returned directly to affected consumers.
AFSA supports directing money collected for alleged legal violations back to impacted consumers. However, it expressed concerns over the CFPB's management of the Civil Penalty Fund, citing its substantial funding from the Federal Reserve and its ability to levy fines on companies that deny wrongdoing. AFSA argues that allowing the CFPB discretion over fund usage fosters a culture lacking accountability and oversight within the Bureau.