CFPB Kept Wise's Redress but Killed the Penalty. That Is the Signal.

The CFPB Just Rewrote Its Own Consent Order — and the Math Tells the Story

On January 30, 2025, the CFPB issued a consent order against Wise US Inc. under docket 2025-CFPB-0004, resolving claims that the remittance company advertised inaccurate fees and failed to properly disclose exchange rates and other costs. The order required Wise to provide approximately $450,000 to harmed consumers and pay a $2.025 million civil money penalty to the Bureau's victims relief fund, as detailed in the CFPB enforcement record.

Then, on May 15, 2025, the Bureau did something unusual. It issued an Amended Consent Order, signed by Acting Director Russell Vought, that superseded the original in its entirety and slashed the civil penalty from $2.025 million to $44,955 — a reduction of roughly 98 percent. The $450,000 in consumer redress stayed exactly where it was.

That split is the entire story. The Bureau kept the money that goes to consumers and abandoned the money that punishes the company. Here is what happened, why it matters, and how to read the signal it sends to every nonbank payments firm in the country.

The Redress Survived. The Deterrence Did Not.

Civil money penalties and consumer redress serve two different functions, and readers who treat them as one blur the real message here.

Redress makes the consumer whole. The approximately $450,000 Wise agreed to return corresponds to actual overcharges — prepaid card violations alone resulted in at least 16,000 consumers being overcharged. That figure did not move in the amendment.

A civil money penalty punishes the conduct and deters repetition. It is the price of getting caught, and it is the part designed to change behavior industry-wide. That figure fell from $2.025 million to $44,955.

When a regulator preserves restitution but dismantles deterrence, it is telling the market something specific. The violations were real enough to require refunds. But the Bureau under its new leadership no longer views punishing them as a priority. For a company with roughly 3 million U.S. customers and about $157.3 million in remittance and prepaid revenue between April 2022 and March 2023, a $44,955 penalty is not a deterrent. It is a rounding error, as noted in Banking Dive's coverage.

The Legal Scaffolding Behind a 98 Percent Cut

The amendment did not simply announce a smaller number. It built a legal record for the reduction, and that record is where the enforcement signal lives.

The Bureau tied the revised penalty to 12 U.S.C. § 5565(a)(2)(H) and (c)(4), the statutory factors governing penalty amounts, including good faith and the size of the party's resources. It also invoked two policy shifts.

The two policy anchors

• Executive Order 14219, issued February 19, 2025, directed federal agencies to review regulations for consistency with law and to identify rules for potential repeal. The Bureau cited it as authority for recalibrating the penalty.
• The rescission of Circular 2024-02. Consumer Financial Protection Circular 2024-02, titled 'Deceptive Marketing Practices About the Speed or Cost of Sending a Remittance Transfer' and published at 89 FR 27357, was rescinded effective May 12, 2025 — three days before the amended order.

The timing is not accidental. The Bureau withdrew the interpretive guidance that framed exactly this kind of remittance-marketing conduct as deceptive, then reduced the penalty for that conduct days later. The original January 30 order was finalized under prior leadership. The amendment reflects a deliberate change in posture, not a clerical correction.

How Payments and Remittance Firms Should Read This

This lens matters most for nonbank payments and remittance providers trying to calibrate risk. Reading a single reduced penalty as a green light would be a serious mistake.

What the signal actually means

First, the substantive liability did not disappear. Wise still had to fund approximately $450,000 in redress, and the findings — inaccurate fee advertising and inadequate disclosure of exchange rates and costs — remain on the record. The conduct was still treated as a violation.

Second, redress is now the enforcement floor, not the ceiling. The current Bureau appears willing to negotiate penalties aggressively while insisting consumers are made whole. Firms should not assume future penalties will be nominal, but they should expect restitution to be non-negotiable.

Third, the disclosure obligations under the Remittance Transfer Rule are unchanged. Rescinding a circular does not repeal the underlying rule. Exchange-rate and fee-disclosure requirements still bind every covered provider.

Concrete steps to take now

1. Audit your fee and exchange-rate advertising against what customers actually pay at settlement. Discrepancies are the exact conduct at issue in the Wise order.
2. Document your disclosure logic for total cost, including the exchange rate margin, before funds are sent.
3. Do not rely on the rescission of Circular 2024-02 as a safe harbor. The statutory prohibition on deceptive practices under the Consumer Financial Protection Act survives the guidance.

We examined the deterrence collapse in more depth in our prior analysis of the Wise penalty reduction, and the amended order confirms the pattern rather than reversing it.

Key Takeaways

• The penalty fell 98 percent while redress held steady. The CFPB cut Wise's civil money penalty from $2.025 million to $44,955 but preserved the approximately $450,000 in consumer redress, separating deterrence from restitution.
• Rescinding guidance is not the same as repealing a rule. The withdrawal of Circular 2024-02 removed interpretive framing, but the Remittance Transfer Rule and the CFPA prohibition on deceptive marketing still apply.
• The amendment reflects a leadership posture shift, not an error. Signed by Acting Director Russell Vought and anchored to Executive Order 14219, the May 15, 2025 order deliberately recalibrated enforcement priorities.
• Restitution is the new floor for payments firms. The Bureau appears willing to negotiate penalties down sharply, but insists consumers are made whole — plan compliance budgets accordingly.
• Fee and exchange-rate disclosure remain the enforcement trigger. The conduct that produced the Wise order — inaccurate fee advertising and inadequate cost disclosure — is still a live violation for every covered remittance provider.