The Bureau Ordered $95 Million Back to Troops.

The Military Lending Act is not a new or ambiguous law. Congress passed it in 2006 after finding predatory lenders were clustering around military bases, charging triple-digit interest rates to troops whose steady paychecks and difficulty defaulting — a service member who stiffs a creditor can face a security-clearance review or even discipline — made them easy marks. The statute, codified at 10 U.S.C. § 987 and implemented through 32 C.F.R. Part 232, caps the Military Annual Percentage Rate — MAPR, which bundles in most fees, not just the sticker interest rate — at 36% on covered loans. A 2015 amendment broadened what counts as "covered" to close off the workarounds lenders had found in the original, narrower version.

A rate cap is only as real as the agency checking whether anyone's obeying it. For the last year, that agency has been checking less, checked less publicly, and in at least one specific, documented case, actively let a violator off a bill it had already been ordered to pay. This is the story of what happened to enforcement, told through the paper trail — court and agency filings, a Federal Register notice, and a Senate letter that's been sitting unanswered for a year.

01The Order: $95 Million, Then Zero

On November 7, 2024, the CFPB ordered Navy Federal Credit Union — the largest credit union in the country, built specifically to serve military members and their families — to pay more than $95 million over illegal overdraft fees charged between 2017 and 2022. The order broke down into two pieces: roughly $80 million in direct restitution to affected members, and a $15 million civil penalty paid into the CFPB's victims relief fund. The underlying conduct was "authorized positive, settle negative" overdraft charges and delayed peer-to-peer transfer fees — the kind of mechanics buried in account terms that most customers never read closely enough to catch.

On July 1, 2025, Acting Director Russell Vought terminated that order. The CFPB's own enforcement-action page now states, in full: the Bureau "terminated the order and waived any alleged non-compliance therewith," citing its own statutory authority under 12 U.S.C. § 5563(b)(3) to do so. That is the entire public explanation. No finding that the underlying conduct never happened. No claim Navy Federal had already paid restitution some other way. Just a citation to the section of law that lets the director waive an order, and the fact that he did.

Trade press covering the reversal — Law360, Banking Dive, and CU Times among them — frame it as one entry in a much longer list: multiple outlets report Vought withdrew or dismissed more than half of the enforcement docket the CFPB was carrying when he took over as acting director. Navy Federal was not a special case. It was one of many, and it happened to be the one involving service members specifically.

The order didn't expire. It didn't get overturned on appeal. Someone with the authority to waive it, waived it.

02Eight Senators, One Deadline, No Answer

On July 16, 2025, eight Senate Democrats — Ruben Gallego, Angela Alsobrooks, Catherine Cortez Masto, Tammy Duckworth, Chris Van Hollen, Raphael Warnock, Elizabeth Warren, and Ron Wyden — sent Vought a formal letter demanding "the full legal and factual basis" for terminating the Navy Federal order, with a response deadline of July 30, 2025. The letter is pointed in a specific way: it directly asks whether the CFPB's own Office of Servicemember Affairs — the internal unit that exists to advise on exactly this kind of decision — was consulted before Vought acted.

Your abrupt reversal of this consent order suggests your stated commitment to protecting servicemembers is little more than lip service.

— Senate letter to Acting Director Vought, July 16, 2025

The July 30 deadline passed a year before this piece was published. We could not find any public record of a written response from the CFPB or from Vought personally. The same eight senators followed up on August 28, 2025 with a separate letter sent directly to Navy Federal's CEO, giving the credit union its own September 12, 2025 deadline to explain what it planned to do about the fees it was no longer legally required to return. We could not confirm whether Navy Federal responded to that letter either. Absence of a public record is not proof nothing happened behind closed doors — but a year of silence, on the record, is itself the current status of this story.

03The Rule That Let It Look Before It Got Robbed

The Navy Federal reversal didn't happen in isolation. On May 12, 2025, the CFPB published a Federal Register notice withdrawing 67 guidance documents issued since 2011 — seven interpretive rules, eight policy statements, 13 advisory opinions, and 39 other guidance documents — in one blanket action. Among them: the June 2021 interpretive rule titled "Examinations for Risks to Active-Duty Servicemembers and Their Covered Dependents" (86 FR 32723), which had reaffirmed the Bureau's authority to proactively examine lenders for MLA compliance rather than waiting for a complaint or a lawsuit to trigger scrutiny.

The notice itself is careful to say the withdrawal "is not necessarily final" pending further Bureau review — but it also states withdrawn guidance "should not be enforced or otherwise relied upon" in the meantime. As of the most recent reporting we could confirm, from the Consumer Federation of America in late 2025, that limbo status hadn't changed: not reinstated, not made permanent, just withdrawn and unresolved. Separately, per that same advocacy-org reporting — which we could not independently confirm against a primary government source, so treat it as reported rather than established fact — the Bureau issued broad staff reduction-in-force notices on April 17, 2025, and the CFPB's Office of Servicemember Affairs was effectively reduced to a single remaining staffer who was placed on administrative leave ahead of a planned retirement. A GAO report on the CFPB's broader 2025 reorganization, GAO-26-108448, confirms the agency-wide restructuring occurred but doesn't break out the Office of Servicemember Affairs specifically in the portion we reviewed.

04The Violations That Kept Coming

Here is the part of the story that cuts against a simple "nobody's watching anymore" narrative, and it matters for getting this right: enforcement didn't stop entirely. On July 11, 2025 — ten days after the Navy Federal order was voided — the CFPB settled with pawn lender FirstCash Inc. and 19 subsidiaries for $9 million ($5 million in servicemember redress, $4 million in penalties). The Bureau's own press release describes "thousands" of unlawful pawn loans made to covered borrowers above the 36% MAPR cap dating back to October 3, 2016.

This wasn't the first time a lender had been caught doing something similar. On February 23, 2023, the CFPB ordered title lender TitleMax (TMX Finance) to pay a $10 million penalty plus $5.05 million in consumer redress over 2,670 loans made to covered military borrowers between October 2016 and September 2021 — the CFPB's complaint alleged that in some cases, TitleMax employees falsified borrowers' information specifically to conceal their military status and dodge the cap. A private class action, Blackmon v. TitleMax (N.D. Ga., filed February 2024 by an active-duty spouse), separately alleges the company kept charging APRs between 100% and 152% after that consent order was already in place; court records we could access show an answer was filed in the case in January 2025, indicating it was still active at that point, though we could not independently verify its current status through a direct court-docket source.

And on November 24, 2025, months after the interpretive rule withdrawal and the Navy Federal reversal, a federal court entered a stipulated final judgment against fintech lender MoneyLion: $1.75 million in consumer redress over allegations it used undisclosed membership fees to functionally push effective rates on covered loans above the 36% cap, and made it difficult for members to cancel and stop the fees. Notably, that judgment carries no separate civil penalty — just redress, and no admission of wrongdoing.

The cap is still the law. Companies are still getting caught breaking it. What's changed is what happens after they get caught.

05No Name, Just Numbers

We looked for an individual service member to put a face on this — someone who paid the overdraft fees Navy Federal was ordered to return, or who took out one of the FirstCash pawn loans priced above the legal cap. We didn't find one we could verify and name. The CFPB's consumer complaint database redacts identifying information by design, and neither the Navy Federal nor FirstCash matters produced a named plaintiff in the public record we could locate. The closest thing we found was a single anonymized CFPB complaint, reportedly filed by a servicemember near Joint Base San Antonio–Lackland describing overdraft fees triggered by a pended transaction — cited secondhand in Consumer Federation of America reporting, not something we pulled directly from the database ourselves. We're reporting that gap honestly rather than filling it with a composite or invented example. This story stands on the institutional numbers: a $95 million order, a 36% statutory cap, and a year of unanswered questions.

06This Has Happened Before

The 2025 rollback isn't the first time the CFPB has stepped back from dedicated MLA supervision. In January 2019, the advocacy group Democracy Forward filed a FOIA lawsuit against the CFPB and the Department of Defense, seeking records on the Bureau's earlier decision, under then-Director Kathy Kraninger, to stop its dedicated MLA examination program. The specifics of the CFPB's stated reasoning at that time didn't hold up cleanly under our own verification pass, so we're not characterizing them here — what we can confirm is that the 2019 FOIA suit itself is real, and that scaling back proactive military-lending oversight is a pattern this agency has repeated across two different administrations, not a one-time event.

07Timeline

08The Bigger Pattern

This is not a story about the 36% cap disappearing. It's still the law. It's a story about the difference between a rule existing and a rule being checked. For four years, the CFPB told lenders it could show up and look without waiting for a complaint. As of this writing, it hasn't said it still can, and its own former servicemember-affairs staffing was reportedly reduced to a single person on the way out the door. Meanwhile, a signed order requiring a $95 million payout to military families sits terminated, unexplained, and unanswered — a year past the deadline eight U.S. senators set for a response.

We're tracking three specific things from here: whether CFPB or Navy Federal ever produces a public response to either senators' letter, whether the May 2025 interpretive-rule withdrawal gets finalized or reversed, and whether any additional MLA enforcement actions surface. Any of the three would change this story materially. We will update this piece when they do.

If you work in military lending compliance, filed a complaint against Navy Federal, FirstCash, TitleMax, or MoneyLion, or have direct knowledge of how any of these decisions got made, we want to hear from you. Anonymously, if that's how you want it. On the record if it's not.