A federal district court recently granted the unopposed motion of the Department of Justice (DOJ) and the Consumer Financial Protection Bureau (CFPB) to terminate their October 2021 consent order with Trustmark National Bank (Trustmark) and to dismiss with prejudice the redlining case they brought that resulted in that consent order.

As previously reported, the agencies, along with the Comptroller of the Currency, announced the consent order at the same time that the DOJ announced its initiative to combat redlining.

By its terms, the consent order was scheduled to end in October 2026, unless Trustmark had not fully invested the loan subsidy fund provided for in the consent order, in which case it would have continued until three months after Trustmark fulfilled that obligation and submitted a confirming report to the DOJ and CFPB.

Supporting the request for the early termination, the unopposed motion provides that “Trustmark has demonstrated a commitment to remediation, and:

1. Trustmark has fully disbursed the loan subsidy fund ($3,850,000) as required under the terms of the Consent Order;
2. Trustmark paid a $5,000,000 civil money penalty as required under the terms of the Consent Order, of which $1,000,000 was paid to the Bureau and $4,000,000 was remitted after Trustmark paid that amount to the [OCC] as satisfaction of its obligation to pay that amount in penalties to the OCC for related conduct; and
3. Trustmark is substantially in compliance with the other monetary and injunctive terms of the Consent Order.” (Citations omitted.)

The motion also indicates that the DOJ and CFPB conferred with counsel for Trustmark, and that Trustmark did not oppose the motion.

In what appears to be a related development, it was recently reported that the CFPB reduced the $2.025 million civil money penalty imposed on Wise, an international remittance company, in January 2025 to slightly less than $45,000.

As previously reported, the CFPB is also seeking to reverse the November 2024 consent order with Townstone Financial, a much more significant step than the early termination of the Trustmark consent order.

While the Townstone development seems to be unique, the actions regarding Trustmark and Wise are nevertheless a clear indication that the CFPB is reassessing various enforcement actions it took under the prior Administration.