The Consumer Financial Protection Bureau’s (CFPB) latest enforcement tool— “substantial assistance” —is becoming a common way for the agency to go after parties that might otherwise escape its reach. In the past year, the CFPB has started to bring such claims with increasing frequency. To date, its enforcement actions suggest that it intends to use substantial assistance claims both as a fallback when other claims fail and as a way to extend its jurisdictional reach where other theories are unavailable. This Legal Update takes a close look at what “substantial assistance” is and how the CFPB has been relying on it.
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