The investors claim the warehouse lenders and underwriters were aware of fraud at Tricolor, but ignored the warnings.

The consent order could have little effect as Luminate Home Loans was folded into Luminate Bank last year and continues to originate mortgages.

The Mortgage Bankers Association said it believes the CFPB's complaint database would be most effective if it functioned as a “secondary escalation mechanism,” available after a consumer has attempted to resolve the issue directly with the company.

Industry attorneys said it looks like the full DC Circuit will send the National Treasury Employees Union lawsuit against the CFPB back to the district court, mandating a revision of the preliminary injunction.

The Mortgage Bankers Association said the CFPB consumer database should not act as an alternative to leaving reviews on Google, Yelp or the Better Business Bureau.

Chris Willis, a partner at the law firm of Troutman Pepper Locke, said the CFPB is likely to resume investigations into pending enforcement actions.

Industry attorneys see 2025 as a “ramp up period” as certain states look to fill the federal enforcement void.

Consumer advocates said Texas-based developer Colony Ridge’s $68 million proposed settlement with the DOJ and the state’s AG doesn’t provide relief for the harmed consumers.

If enacted as proposed, the rule would impose substantial regulatory requirements onto buy now, pay later providers.

The regulator said the Fair Housing Home Loan Data System regulation was obsolete and largely duplicative of and inconsistent with other data collection regimes.