The Prisoner’s Dilemma Comes for Corporate Crime

On April 16, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule revising its procedures for establishing supervisory authority over nonbank financial institutions on the basis that the institution poses a risk to consumers. In 2023, the CFPB initiated its first round of supervisory designation procedures under the old rules, and in February 2024 made public the order stemming from its first contested proceeding. Although this update seeks to make the designation process...
By: Cooley LLP

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