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The first 100 days of the second Trump Administration
In its first 100 days, the second Trump Administration has made substantial strides in reshaping financial regulation around a deregulatory, pro–innovation agenda. While the deregulatory posture is familiar from the Administration’s first term, the current approach reflects a more systematic and coordinated strategy, supported by aligned leadership across the regulatory agencies, a unified Congress and a judiciary increasingly skeptical of agency discretion. Each of these institutions has played a role in rolling back Biden Administration rules and policies, contributing to a near–term easing of compliance burdens and foreshadowing a longer–term shift in how regulatory power is exercised and contested.
- The executive branch has driven this transformation through a series of Executive Orders (EOs), including those that asserted centralized executive oversight of independent agencies and empowered the new Department of Government Efficiency (DOGE) to reduce agency workforces. Further EOs directed the agencies to work with DOGE and the Office of Management and Budget (OMB) to review their regulations for “consistency with law and Administration policy” and plan for large–scale reductions in force.
- Meanwhile, the agencies have not waited for the confirmation of permanent leaders to begin redirecting Biden Administration priorities – like aggressive consumer protection and climate risk management – to creating an enabling environment for digital asset adoption, AI integration and bank–led innovation. The CFPB has experienced the most significant change, with acting leadership halting rulemaking, pausing enforcement activity and withdrawing from litigation challenging past rulemaking. The other financial regulators have rescinded guidance issued by their predecessors and narrowed their enforcement posture to focus on clear violations of law, fraud, and demonstrable harm.
- Congress has complemented these executive and agency actions by advancing Congressional Review Act (CRA) resolutions to repeal late Biden–era CFPB rules on overdraft fees and large digital payment provider oversight. Both chambers have also made significant progress on bipartisan legislation to create a regulatory framework for dollar–backed stablecoins.
- The judicial branch is reinforcing these changes by limiting agency authority through rulings and procedural scrutiny. Federal courts have struck down SEC rules expanding requirements for private funds and the definition of a “dealer.” There is also ongoing litigation against the SEC’s climate risk disclosures and the CFPB’s Dodd– Frank Act (DFA) Section 1071 small business lending rule and DFA Section 1033 open banking rule, all of which current agency leadership have declined to defend.
This Our Take Special Edition details actions by these actors over the last 100 days across the following topics:
- FPB cut and curtailed
- Financial risk rules revisited
- Crypto reaches a crescendo
- Regulatory reversal on reputational risk
- Clearing the way for M&A and innovative models
- The age of AI
- Financial crimes shift focus
- Community Reinvestment Act modernization no more
- Regulators cool on climate risk
- Sea change at the SEC and CFTC
Together, changes across these areas give firms more flexibility to chart their own course and pursue growth strategies – but that freedom must be exercised with sound risk management and awareness that legal, supervisory, and reputational consequences still apply.
See full report here.
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