Fintech Takes x FairPlay Presents Model Citizens: Into the CFPB Void: Regulatory Free-for-All in Financial Services

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Jul 28, 2025

Guest

Kareem Saleh

Join David Silberman, former CFPB Associate Director, Abby Hogan from FairPlay, and CEO Kareem Saleh as they dive into the challenges of the current financial regulatory landscape. They discuss the implications of a weakened CFPB and the rising influence of state regulators. Explore how a complex patchwork of compliance is developing, why 50-state rules can be a costly burden, and the potential for rebuilding the CFPB. The conversation highlights the critical need for fairness in lending amidst rapid AI integration in the industry.

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INSIGHT

States' Diverse Regulatory Roles

The state regulators have varying authority depending on the type of financial institution involved.
National banks are mostly federally regulated while fintechs and non-depositories face significant state oversight.

INSIGHT

Complexity of Multi-State Compliance

Complying with 50+ state laws is more complex than federal regulation.
Each state has differing requirements, making compliance costly and resource intensive for fintech companies.

INSIGHT

CFPB's Talent Pool Dispersion

CFPB attracted highly talented staff with a mission-driven culture and startup-like environment.
Many former CFPB staff have migrated to advocacy, regulatory, law firms, and fintech, spreading consumer-centric mindsets.

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Welcome to Model Citizens: AI Compliance for Banks and Fintech Lenders, a six-part miniseries from the Fintech Takes podcast in partnership with FairPlay.

In this series, I’m joined by FairPlay’s Kareem Saleh (Founder & CEO) to explore how banks and fintechs can build fair, compliant lending systems in an era of regulatory uncertainty.

Episode 1 tackles one of the biggest questions in financial services today: what happens when the top federal watchdog (that was/is the CFPB) loses its bite?

Joined by David Silberman (former CFPB Associate Director for Research, Markets, and Regulation) and Abby Hogan (SVP of Legal & Regulatory Affairs; ex-CFPB), we explore the vacuum left by a defanged CFPB and the new patchwork of enforcement that’s emerging in its place.

Highlights include:

Why 50-state compliance is the most expensive form of “deregulation” you’ve never asked for

How pragmatic state regulators are becoming the new R&D lab for rulemaking since fintech innovation won’t wait

What the five-year lookback really means for compliance teams (hint: regulatory whiplash isn’t a free pass to hit cruise control)

Whether the CFPB could be rebuilt (and how fast the talent might come roaring back)

This episode sets the stage for what’s ahead. Because the future of fair lending isn’t just about algorithms; it’s about who’s making the rules, who’s watching, who’s suing, and who’s redrawing the lines of fairness and risk.

In other words: it’s about what kind of model citizens we want our institutions (and our systems) to be.

Don’t forget to subscribe and catch more insights on Model Citizens in upcoming episodes!

This miniseries is brought to you by FairPlay.

FairPlay is an AI enablement company for financial services. They help companies build, test, optimize, validate and govern AI models. Learn more at Fairplay.ai

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