17
CFPB to run it. We already have it in place,
and they are doing the exact type of regulatory
investigative work on the statewide level that
the CFPB does on a national level.
I think you are going to see more states
do that as well, and I understand why. ere's
a perception out there amongst some in
the legal community that the CFPB is not
enforcing things the way it did under prior
years. ere's a perception among various state
attorneys general that they are needed to fill a
perceived void in enforcement. We have seen a
stepped-up enforcement in Pennsylvania. Our
Department of Banking and our Office of the
Attorney General have certainly concentrated
more on borrower and consumer protection.
And I understand why.
In times like this, with higher
unemployment and a crisis on a national
level, the attorneys general and the regulatory
bodies are going to want to look out for
borrowers and consumers. is is one of the
natural repercussions you are going to see of
that: an enhanced regulatory environment and
additional bodies like mini-CFPBs popping up
around the country.
However, once those are created, they're not
just going to go away when COVID-19 ends.
So there is just another regulatory layer—and a
double layer of enforcement, ultimately—that
services are going to have to be on the lookout
for it. You are going to have to deal with the
AGs, the CFPB, mini-CFPBs, and others, so
ultimately it may actually further complicate the
process. With a new administration in place, I
expect that CFPB enforcement by regulation
and legal action will increase, and there will be
more joint CFPB-state enforcement actions.
"There's a perception
among various state
attorneys general
that they are needed
to fill a perceived
void in enforcement."
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