Steven M. Kaufmann and Natalie A. Fleming Nolen
Banking + Financial Services, Financial Institutions + Financial Services, Financial Services Litigation, Financial Services Enforcement, Financial Services, Financial Technology, Mobile Payments, and Mortgage
In its third Request for Information to “ensure the Bureau is fulfilling its proper and appropriate functions to best protect consumers,” the Consumer Financial Protection Bureau seeks comments “to help assess the overall efficiency and effectiveness” of its enforcement process. We issued client alerts previously on the CFPB’s outreach and RFI process, the first RFI relating to Civil Investigative Demands, and the second RFI on administrative adjudications. All three of the RFIs seek to address primary criticisms that the Bureau’s enforcement process has been overzealous and an inappropriate burden on the financial industry. Respondents may well address the issues in all three related RFIs together. The comment period on this RFI will run for 60 days after the RFI is published in the Federal Register, which is anticipated to happen by February 12.
Read our client alert.
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