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68 ere are multiple levels of regulation in the financial services industry with federal, state, and even local officials supervising companies within the industry. ese regulators often cooperate, but also sometimes act in conflict with one another in their pursuit of consumer protection and enforcement of laws. DODD-FRANK INCREASES COOPERATION BETWEEN FEDERAL AND STATE REGULATORS When it was passed in 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank") was the most sweeping piece of financial regulation enacted since the 1930s. Before leg- islators approved Dodd- Frank, consumer protection functions were dispersed among the alphabet soup of federal regulators. But the new law changed that, introducing a single agency—the Con- sumer Financial Protection Bureau—that would increase coordination and ensure more consistent enforcement. Before Dodd-Frank, states often passed laws which attempted to regulate the activity of national banks. In the context of mortgage lending, for example, states like New York and North Carolina passed foreclosure-related legislation early in the financial crisis. But enforcement of these laws was often curtailed by federal regulators, who asserted that the state laws were preempted by federal law. Consumer protection advocates long argued that this inconsistency in the laws was hurting consumers. ese advocates wanted states to have the ability to act independently to achieve their own policy goals based on local conditions. Dodd-Frank ushered in a new level of coordination and cooperation among state and federal regulators, explicitly empowering states by raising the standards that must be met before federal regulators can assert preemption. e relationship between the states and the CFPB, as the single federal consumer protection regulator, is central to this new era of cooperation, which has been especially important in the supervision of non-bank financial service companies. Regulatory authority over non- banks, who were typically supervised exclusively at the state level, changed with the creation of the CFPB. e collision of regulatory spheres since Dodd-Frank could have deteriorated into a turf battle between the Bureau and its state-level counterparts. However, soon after the enactment of Dodd-Frank, the CFPB entered into agreements with state regulators to help foster cooperation. Tracing the development of these state-federal relationships helps explain the tenor of financial services regulation as it stands today, as well as where the industry is headed. Conference of State Bank Supervisors e first of these major agreements was signed in early 2011 between the Conference of State Bank Supervisors (CSBS) and the CFPB. In this agreement, the parties established the foundation for state and federal coordination for supervision of providers of consumer financial products and services. In May 2013, the CSBS and the CFPB built on this agreement by signing a Supervisory Coordination Framework, which established a process for coordinated federal/state consumer protection supervision and enforcement. e intent of the agreement was to have the parties work together to achieve examination efficiencies and to avoid duplication of time and resources. R E G U L A T O R Y I N S I G H T / N E A L D O H E R T Y A N D M A R I A M O S K V E R THE UNDERAPPRECIATED IMPACT OF DODD-FRANK: THE RISE OF FEDERAL AND STATE REGULATORY COOPERATION P

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