CFPB Retrospective—Five Enduring Lessons, Even After Cordray’s Departure

This article was co-authored by Andrew Bigart, Partner; and Meredith L. Boylan and Alexandra Megaris, Counsels with Venable LLP.

The resignation of Richard Cordray as director of the Consumer Financial Protection Bureau (CFPB or Bureau) last November marks the end of an era at the often controversial—but never boring—consumer protection agency. Under Cordray’s leadership, the CFPB hit the ground running in 2012 and quickly established a reputation as an aggressive regulator through high-profile enforcement actions and tough examinations of financial services providers. With Cordray’s departure, and President Trump’s appointment of Mick Mulvaney as acting director, it seems the Bureau’s focus will shift, at least in the short term.

Even with change afoot, it’s clear the Bureau’s first five years changed the way consumer financial services providers think about compliance and consumer protection. And while the CFPB may be less aggressive in the near term, the Federal Trade Commission (FTC), banking regulators, and state attorneys general remain active in protecting consumers. The start of 2018 is a good time to review some of the key lessons of the Bureau’s first five years. Even in a deregulatory environment, heeding these basic consumer protection lessons makes business sense and can help minimize potential enforcement risk.

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