Mortgage compliance has entered a new phase as we head towards 2026. The enforcement tone has softened, but complexity has grown. Federal oversight is evolving, state regulators are becoming more active, and technology continues to redefine how lenders manage risk.
At RiskExec’s annual virtual event, RiskExec Connect 2025, Rob Chrisman and Robbie Chrisman of The Chrisman Commentary joined Sarah Brons of RiskExec to unpack what these shifts mean for lenders. Their message was pragmatic: steady, consistent compliance is the smartest path forward in an environment in which rules remain but interpretations change.
Hear directly from Robbie and Rob Chrisman and Sarah Brons as they discuss CFPB transitions, market outlooks, and how technology is reshaping mortgage compliance.
The Consumer Financial Protection Bureau (CFPB) has experienced significant transformation since its founding. As Rob Chrisman noted, each director—from Richard Cordray to Kathy Kraninger, Rohit Chopra, and now Mark Calabria—has left a distinct imprint on how the Bureau defines consumer protection.
Calabria’s appointment, combined with ongoing political turnover, has effectively “defanged” the agency’s enforcement arm, according to the Chrismans. Yet that does not mean risk has disappeared.
“You can’t eliminate the CFPB by waving a wand,” Rob Chrisman explained. “The statutes and rules still exist. They’re just being interpreted differently.”
Lenders who interpreted reduced enforcement as reduced risk may find themselves exposed when the regulatory pendulum swings back. The underlying legal framework remains intact. The smart move is to stay compliant, document decisions, and prepare for eventual reversals.
Both Rob and Robbie Chrisman emphasized that most successful lenders are choosing stability over speculation.
“It’s not about predicting the next administration,” Robbie said. “It’s about staying consistent. The rules haven’t disappeared.”
This mindset echoes a common refrain from compliance leaders: consistency equals protection.
When oversight pauses, the temptation to cut compliance costs increases. But history shows that lenders who do so often become primary targets once enforcement resumes.
The Chrismans recommended four practical steps to maintain stability:
With CFPB enforcement easing, state regulators are stepping up. The Chrismans highlighted that states such as California, New York, Pennsylvania, and Illinois are taking a stronger stance on mortgage servicing, fair lending, and consumer protection.
Some former CFPB personnel now serve within state agencies, bringing federal-level expertise to local jurisdictions. This trend creates a complex, decentralized enforcement environment. Once federal oversight scattered, state regulators quickly moved to fill the space.
Recommended approach: Create a state examination tracker that aligns with existing CFPB requirements. Standardize documentation so the same data supports multiple oversight bodies.
Artificial intelligence and automation have become essential to mortgage operations. From underwriting and servicing to borrower communication, technology offers speed and efficiency—but also introduces new types of risk.
Robbie Chrisman pointed out that many regulators are still catching up to what these systems can do. This gap between innovation and oversight makes transparency critical.
“Regulators can’t regulate what they don’t understand,” Robbie said. “It’s up to lenders to explain how their systems make decisions, if they are leveraging AI within their processes.”
The Chrismans and Brons agreed that data transparency is becoming a business advantage for many financial institutions.
Investors, secondary market participants, and auditors increasingly value institutions that can demonstrate clear, defensible compliance controls.
Rob Chrisman explained it simply: “Investors… buy from lenders who can prove they did things the right way.”
Compliance technology now does more than mitigate risk. It creates trust with partners and regulators alike. And systems that unify HMDA, CRA, and Fair Lending data provide real-time insights that benefit both operations and audit readiness.
The Chrismans concluded the session by emphasizing that compliance culture is as important as policy.
Younger loan officers entering the industry may not remember the pre-crisis era of 2007–2008, when inconsistent oversight led to widespread losses. But, “Mortgage is a 15-year business with a 10-year memory,” Rob Chrisman said. “Good habits fade faster than they should.”
That institutional memory gap makes ongoing education critical. Compliance leaders should integrate regulatory awareness and fair lending training into all levels of the organization, to avoid issues in the future.
In closing, Rob Chrisman shared a few final practical ideas that institutions may wish to consider:
Yes, current enforcement activity has slowed, but underlying statutes remain unchanged. Compliance programs should remain fully active to prepare for future shifts.
States such as California, New York, and Illinois are expanding their fair lending and servicing oversight, sometimes working together through multi-state task forces.
AI can improve speed and accuracy but introduces model risk and bias concerns. Lenders should document and govern their use of AI to maintain transparency.
