估算消费者金融保护局对消费者的成本

The Council of Economic Advisers February 2026 Key Takeaways •The regulatory burden imposed by the Consumer Financial Protection Bureau (CFPB) has increasedthe compliance and liability costs associated with consumer financial products, which financialinstitutions pass on to consumers in the form of higher prices and reduced product offerings.TheCouncil of Economic Advisers (CEA) estimates that since 2011, the CFPB has cost consumersbetween $237-$369 billion, including fiscal costs, increased borrowing expenses, and reducedoriginations. •Of the total above, CEA finds that increased borrowing costs amount to at least$222-$350 billion1($160-253 per borrower) from the CFPB’s inception in 2011 through 2024. oBroken down by loan type, the CFPB’s rulemaking has cost consumers $116-$183 billion inhigher mortgage costs ($1,100-$1,700 per originated loan), $32-$51 billion for auto loans($91-$143 per loan), and $74-$116 billion for credit cards ($80-$126 per loan). These costssignificantly surpass the CFPB’s reported $21 billion returned to consumers (about $15 perborrower). •In 2024 alone, the CEA estimates the combined annual cost of credit for mortgages, autos, andcredit cards is between$24-$38 billion. •CEA also estimates that the higher borrowing costs from CFPB policies significantly reduced loanoriginations, resulting in an economic efficiency loss of between$1.5-$5.7 billionto consumers. •The annual paperwork burden alone from CFPB rules exceeds29 million hoursor the equivalent of14,100 full-time employees spending all of their time on documentation and reporting requirementsat a conservative cost of just under $2.5 billion. From 2011 to 2024, the Bureau’s paperwork burdencosts have cost businesses$21 billion.2 •The CFPB has received $8.9 billion in total transfers from the Federal Reserve between 2011 and2024 when adjusted for inflation. Since funds transferred to the CFPB would otherwise have beentransferred to the US Treasury, the lost revenue results in a marginal excess tax burden (METB) of$4.4 billion. Taken together, the fiscal cost of the CFPB since inception is over$13 billion. Introduction The Consumer Financial Protection Bureau (CFPB) has steadily expanded its jurisdiction since inception,extending oversight across all consumer credit markets, including mortgages, auto lending, and creditcards. Through a combination of regulation, supervision, and the persistent threat of enforcement, theCFPB has increased the cost of credit for both lenders and borrowers. Moreover, instances of regulatoryoverreach and actions that bypass the Administrative Procedure Act (APA) introduce additional costs anduncertainty into credit markets that can further push lenders to retreat or limit offerings. As a result, theaggregate “dollars returned to consumers” figure of $21 billion that is often cited by the CFPB severelyunderstates the broader burden imposed on the financial system. To estimate the cost of CFPB policies on the U.S. economy, we exploit a natural experiment in themortgage market to estimate the increased cost of credit for loans explicitly subject to CFPB regulations.We find that borrowers of these regulated loans paid on average 4.3% more in interest (or 16 basis points)compared to borrowers not subject to CFPB regulations. Using this cost wedge, we extrapolate increasedborrowing costs for auto loans and credit cards. Across all three forms of consumer credit (i.e., mortgages,auto loans, and credit cards), we find that the CFPB has increased consumer borrowing costs by between$222-$350 billion from 2011 through 2024. Over the same period, economic efficiency losses stemmingfrom fewer loan originations cost consumers an additional $1.5-$5.7 billion.When combined with theCFPB’s cumulative fiscal cost of over $13 billion, the cost of the CFPB on the consumers from inception tothe present day is between$237-$369 billion. In 2024 alone, the combined annual cost of the fiscalburden, increased credit costs, and deadweight losses was between$24.4-$38.1 billion. Politicization of the Regulatory Process at the CFPB In response to the 2008 Financial Crisis, Congress passed theDodd–Frank Wall Street Reform andConsumer Protection Act, establishing the CFPB. In doing so, Congress consolidated the consumerprotection functions of various agencies including the Federal Trade Commission (FTC), Housing andUrban Development (HUD), and various financial regulators into a single agency. Thestated objectiveofthe CFPB, per the CFPB’s chief architect, Sen. Elizabeth Warren (D-MA), is “making markets for consumerfinancial products and services work in a fair, transparent, and competitive manner.” However, frominception, the CFPB has avoided transparency and accountability, opting to regulate markets through itssupervisory and enforcement authorities, which are not subject to the formal rulemaking process (orcongressional review). In addition to the 400 final rules and formal advisory opinions, CFPB has avoidedtransp