The Consumer Financial Protection Bureau (“CFPB”) launched a new system to provide guidance to other agencies with consumer financial protection responsibilities. While the CFPB is the main regulator responsible for administering compliance with the federal consumer financial protection laws, overall enforcement responsibility is spread to a variety of state and federal agencies. As a result, there is a risk of inconsistent enforcement strategies and approaches.
The goal of this new system is to promote consistency and fair competition among the enforcers of consumer financial protection laws. Since entities can be subject to the jurisdiction of multiple agencies, consistency is key to fair competition.
To further its goals, the CFPB will release Consumer Financial Protection Circulars to the broad set of agencies responsible for enforcement. The CFPB issued its first Circular on May 17 addressing the use of the name or logo of the Federal Deposit Insurance Corporation as a deceptive act or practice.
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