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Buckley Sandler C-Suite Financial Services Review: Enforcement Trends - The States Step Up

Buckley Sandler C-Suite Financial Services Review

Andrea K. Mitchell, Michelle L. Rogers, Katherine L. Halliday

The new leadership at the Consumer Financial Protection Bureau has explicitly stated that it expects to pursue fewer enforcement actions than it has in the past. While the anticipated reduction in CFPB enforcement activity may cause some companies to feel a sense of relief, there may be less cause to celebrate than we might think. As the CFPB curtails enforcement activity, the states have already begun ramping up their efforts to close the gap with an open invitation to do so by the bureau. Indeed, Acting Director Mick Mulvaney publicly stated in February 2018 that he would depend heavily on state attorneys general to enforce consumer protection laws.

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