Worried About FTC and CFPB Overlap? Don't – They Pledge to ‘Work Together’
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The Consumer Financial Protection Bureau (CFPB) – which refers to itself as “a 21st century agency that helps consumer finance markets work by making rules more effective, by consistently and fairly enforcing those rules, and by empowering consumers to take more control over their economic lives” – already has shown that it will not be a shrinking violet when it comes to exercising its authority. Given that, it’s only reasonable to wonder how well the CFPB might work with other federal agencies with which it shares responsibilities. Now, we know – at least with respect to the CFPB and the FTC.
That’s because the two groups have signed a Memorandum of Understanding to coordinate efforts – and to avoid duplication – of federal law enforcement and regulatory efforts.
Dodd-Frank, which created the CFPB, requires the CFPB and the FTC to work together to coordinate their enforcement activities and promote consistent regulatory treatment of consumer financial products and services. In the Memorandum of Understanding, which supplements the requirements of the Dodd-Frank Act, the agencies have agreed to:
•Meet regularly to coordinate upcoming law enforcement, rulemaking, and other activities.
•Inform the other agency, absent exigent circumstances, prior to initiating an investigation or bringing an enforcement action. This notice will prevent duplicative or conflicting enforcement efforts and undue burdens on industry.
•Consult on rulemaking and guidance initiatives to promote consistency and reflect the experience and expertise of both agencies.
•Cooperate on consumer education efforts to promote consistency of messages and maximum use of resources.
•Share consumer complaints.
Of course, it will take time to see how this plays out in practice.
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