Businesses that are regulated, supervised, and examined by the CFPB likely know what to expect now under Director Kathleen Kraninger, whose term does not end until 2023. She may, of course, be reappointed or be succeeded by a like-minded director who serves another five-year term. But, there is also another possibility. “Elections have consequences”, the saying goes. On that point, Eric Mogilnicki and David Stein, attorneys at Covington, wrote an article designed to help businesses prepare for a “what if”. What if the “CFPB changes course — in perspective, personnel and policies — as soon as 2021. Such change is not a foregone conclusion, and so what follows is a look down a path that the bureau may not take. But looking down that alternate path is an important exercise for any financial institution that does not want to risk being unprepared a year from today.”
Eric J. Ellman is Senior Vice President for Public Policy and Legal Affairs at the Consumer Data Industry Association (CDIA) in Washington, DC. He also served for eight months as Interim President and CEO of the Association. More