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Mike G. Silver Weighs in on the State of the CFPB for Multiple Publications

January 6, 2026

Spencer Fane attorney Mike G. Silver lent his insights about recent Consumer Financial Protection Bureau (CFPB) activity to Capitol Account, Bloomberg Law, and American Banker.

Mike, a founding member and 12+ year veteran of the CFPB Office of Regulations, was one of several thought leaders sought by the publications to help recap a tumultuous year at the agency, analyzing the CFPB’s choice to pursue an aggressive rulemaking agenda while seemingly ready to cease operations. “You need staff and resources to execute a fulsome rulemaking agenda, even if the agenda is aimed at deregulation,” he shared with Capitol Account for their article, CFPB Races Ahead With Rule Rollbacks as Funds Run Out.

In the Bloomberg Law article, CFPB Funding Question Threatens to Upend New Deregulatory Agenda, Mike explained why the agency’s actions seem so paradoxical: “it seems at odds to amplify your rulemaking agenda while at the same time taking other actions that will force the bureau to run out of money.”

In the American Banker article, It’s All on the Line for the CFPB in 2026, which was republished in Westlaw Today, Mike remarked on the CFPB being at a critical crossroads, with conflicting pressures making the CFPB’s future uncertain. “They’re at a fork in the road, and like Yogi Berra said, ‘Take it,’” he said, quoting the New York Yankees catcher. “The CFPB has to decide whether they want to power up the agency and go through the process of actually writing these rules, or choose the dissolution of the agency.”

Mike also discussed this topic in depth with a firm blog post.

At the firm, Mike is a financial services and fintech advisor and thought leader who helps clients navigate regulatory labyrinths and uncertainties. Drawing on more than two decades of private and public sector experience in the nation’s capital, Mike counsels banks, credit unions, mortgage lenders, fintech companies (from early-stage to established), and other financial services clients on regulatory compliance, product counseling, and policy advocacy.

Spencer Fane
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