IN LATE 2017, then Acting Director Mick Mulvaney
announced that the Consumer Financial
Protection Bureau (CFPB) was unlikely to
engage in enforcement actions under his
watch to the extent that it had under former Director Richard Cordray. 1 Further, he
stated that he would look to the states to fill
in that gap to the extent necessary—a direct
reference to the concurrent enforcement
structure built into the Dodd-Frank Act.
BY SAM HOLLE, CRCM, AND
THERESE KIEFFER, J.D.