Our lawyers have significant experience counseling and representing clients before the Consumer Financial Protection Bureau (CFPB). Since its creation by the Dodd-Frank Act, and its opening in July 2011, the CFPB has played a substantial role in the regulation of consumer financial products and services offered in U.S. markets. The CFPB’s approach, often regulating through enforcement rather than formal regulation, presents great uncertainty to those entities providing consumer-facing financial products and services, including through the CFPB’s unusual power to declare otherwise legal practices unfair, deceptive or abusive (UDAAP).
Since its founding, Manatt has been a leading banking firm in California, and across the nation. Manatt’s national consumer financial services practice offers its clients experience dealing with the CFPB in response to civil investigative demands (CID’s), notice and opportunity to respond and advise (NORA) letters, and Potential Action and Request for Response (PARR) letters.
In addition to our work on behalf of clients facing scrutiny from the CFPB, we also advise clients in preparing for CFPB examinations, responding to and implementing CFPB regulatory proposals and vetting new products and services. Supplementing our already robust compliance practice, our due diligence teams perform reviews to ensure that companies are well prepared for any CFPB examination and assist clients in enhancing their compliance programs to avoid enforcement scrutiny.