The Consumer Financial Protection Bureau (CFPB) continues to
prosecute bad actors in much the same way as they did before
acting director Mick Mulvaney took over from Richard Cordray.
This is despite loud claims to the contrary and suggestions
that the bureau would cease to function in its previous
While the number of enforcement actions actually brought by
the CFPB has dropped since Mulvaney assumed the position in
November 2017, the substance of those actions and the types of
claims that are being made has remained much the same.
"The nature of the claims and the legal arguments that they
are making are basically the same as they were before, even in
areas where Mulvaney has suggested that he thought that the
bureau was acting improperly, overreaching or not providing
fair notice to companies about what is or what
isn’t prohibited," said
Mayer Brown partner Ori Lev.