A substantive and statistical analysis of the Consumer Financial Protection Bureau’s 62 publicly available enforcement actions to date reveals preliminary trends and patterns.
Established in 2011 in the wake of the financial crisis, the Consumer Financial Protection Bureau (CFPB or the Bureau) is charged with enforcing a number of federal consumer financial protection laws, including Title X of the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act of 2010 (Dodd-Frank) — which includes a prohibition against unfair, deceptive or abusive acts or practices (UDAAP) in connection with transactions for consumer financial products; the Telemarketing and Consumer Fraud and Abuse Prevention Act; several rules issued by the Federal Trade Commission;1 and 18 other pre-existing consumer financial protection laws.2 This White Paper examines the CFPB’s first 62 publicly disclosed enforcement actions3 over the past three-and-a-half years.4 This examination allows us to identify trends and patterns in the Bureau’s enforcement activities and in the ways in which companies subject to its enforcement power are being affected.
Overview -
Because this analysis is limited to publicly available information, this White Paper does not include Bureau inquiries or actions that have not yet been made public by either the Bureau or the target company. Even with those limitations, however, this review of the 62 public actions provides us with sufficient data to identify the types of companies the Bureau is targeting and the laws the it has sought to enforce; and to evaluate the potential settlement terms and costs facing defendants in CFPB enforcement cases.
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