CFPB, FTC Sign Memorandum of Understanding Coordinating Enforcement, Rulemaking
On January 23, 2012, the CFPB and the FTC signed the long-awaited Memorandum of Understanding (“MOU”) outlining the contours of its joint enforcement and rulemaking authority under Dodd-Frank. The MOU sets forth the CFPB and FTC’s procedures for coordinating enforcement actions and rulemakings, interagency notice requirements before commencing actions against regulated entities and information-sharing. The MOU also includes a provision for the CFPB to share the results of its nonbank supervisory and examination activities with the FTC.
The CFPB and the FTC faced stiff criticism from the U.S. Chamber of Commerce and other business groups regarding the MOU’s delayed release nearly two years after Dodd-Frank was signed.
A copy of the MOU is available here.