Within a span of 30 days toward the end of 2016, the consumer financial services world absorbed two seismic shocks: the DC Circuit’s decision in the PHH Corp. case, followed by the unexpected election of US President Donald Trump. Both events are virtually certain to affect the Consumer Financial Protection Bureau’s (“CFPB” or the “Bureau”) future enforcement activity. Rumors are swirling that President Trump will attempt to remove the Bureau’s director, Richard Cordray, and appoint someone more industry-friendly, reducing the number of enforcement actions brought by the Bureau. Nevertheless, providers of consumer financial services should not assume that their enforcement risk will disappear along with Cordray. This Legal Update discusses how state attorneys general will almost certainly seek to fill any void left by decreased CFPB enforcement.
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