Revisiting Dodd-Frank: 15 Years of Regulation, Reform, and Roadblocks

In July, 2025, America’s Credit Unions sent a comprehensive letter to the House Financial Services Committee, addressed to Chairman Rep. French Hill and Ranking Member Rep. Maxine Waters. The letter marks a firm and focused request: it’s time to revisit the Dodd-Frank Act along with the structure and accountability of the Consumer Financial Protection Bureau (CFPB).
 

Now, over a decade since Dodd-Frank’s passage, the financial landscape and regulatory burdens have both evolved, and the letter highlights how community-based financial institutions like credit unions have faced disproportionate challenges navigating the complex compliance environment that followed the 2008 financial crisis. While the intention of the Act was to protect consumers and prevent systemic abuses, the implementation has often left credit unions struggling to fulfill their mission efficiently.

---

Key Challenges Raised by America’s Credit Unions

The letter outlines several areas where reform is not only warranted but also overdue:
 

Credit unions argue that the single-director leadership model of the CFPB invites abrupt policy shifts and lacks the stability needed for long-term planning. The proposed solution? A bipartisan, five-member commission that would allow for broader input, more balanced decision-making, and continuity through political transitions.
 

To increase accountability, the association recommends that the CFPB be subject to the congressional appropriations process and supports an independent Inspector General (IG). This IG would be required to testify annually, creating a more structured framework for evaluating the Bureau’s performance and ensuring checks and balances.
 

The Bureau’s use of the “unfair, deceptive, or abusive acts or practices” (UDAAP) standard has raised concerns due to its broad and, at times, unpredictable application. Credit unions are seeking clearer definitions and a more consistent approach. Specifically, they seek formal rulemaking through notice-and-comment procedures before initiating enforcement actions, rather than relying on case-by-case interpretations.
 

The current Civil Investigative Demand (CID) process can be burdensome, overly aggressive, and unclear. America’s Credit Unions recommends streamlining this process to provide recipients with better notice, improved response timelines, and greater transparency.
 

More robust cost-benefit analysis and meaningful engagement with small entities, especially through the Small Business Regulatory Enforcement Fairness Act (SBREFA) process, would help ensure that future rules reflect the realities of smaller, community-based financial institutions.
 

One of the most consequential asks in the letter is the repeal of the Durbin Amendment. Though initially designed to address interchange fees for large banks, its impact has extended to credit unions, limiting revenue, restricting debit card programs, and hampering member service. The association argues that this well-intended provision has done more harm than good to institutions that were never the source of the problems Dodd-Frank aimed to fix.

 

Credit unions have a unique role in the financial services ecosystem as cooperative, not-for-profit institutions rooted in local communities. The one-size-fits-all regulatory regime imposed in the wake of the financial crisis has ignored this distinction. As a result, credit unions get caught in a framework built for the biggest players on Wall Street, despite being among the most consumer-focused institutions in the country.

 

Now that this letter has been submitted, it’s up to Congress to engage in the conversation. Hearings and legislative review may follow, offering an opportunity for policymakers to assess whether the current regulatory regime aligns with its original mission and whether changes are needed to ensure credit unions can continue serving members without undue constraints. However, early signs of momentum are already visible. As of July 24, 2025, the House Financial Services Committee advanced four bipartisan bills that reflect some of the very concerns outlined by America’s Credit Unions. These proposals, aimed at streamlining supervision, clarifying agency guidance, and supporting de novo credit union formation, suggest that lawmakers are actively considering a more balanced and responsive regulatory framework.

---

At Weltman, we support credit unions across the country through our Credit Union Representation Group. We stand alongside credit unions in support of their push for balanced and meaningful reform as they navigate these regulatory challenges. Our team is constantly monitoring updates to this topic. If you have any questions or concerns, please reach out to our credit union team at any time.
 

Thank you to Cleveland Summer Law Clerk Riddhi Modi for writing this article & for her extensive research and support to the Weltman firm!