CFPB Codifies Limited Role of Supervisory Guidance Into Final Rule: What Next?
By EsqSocial Corporation 26/01/21
In one of many last-minute actions likely to be challenged by Democrats, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a final rule “codifying” the September 2018 Interagency Statement (2018 Statement). That statement made clear that supervisory guidance “does not have the force and effect of law, and the agencies do not take enforcement actions based on supervisory guidance.” In this update, we tell you why that matters and offer thoughts on whether Democrats (whether in CFPB...
By: Manatt, Phelps & Phillips, LLP