The CFPB is at a crossroad as it seeks its path forward as a non-political and vigorous consumer protection regulator.

Overview: Enforcement actions by the CFPB have raised profound questions about how the Bureau applies laws that were transferred to it under the Dodd-Frank Act. The Bureau has published key consent orders and decisions-including under RESPA-that diverge from prior rules and interpretations of the Department of Housing and Urban Development (HUD) that the industry has relied on for decades. Guidance documents issued by the Bureau have their value diminished by disclaimers that such guidance cannot be relied upon. This has increased the potential for confusion amongst the regulated entities. While the Bureau has taken a public step away from the CFPB's old mantra, it is important for the CFPB to take steps towards adopting a consistent framework for providing authoritative written guidance that facilitates compliance, reduces implementation costs, and ensures consistent consumer treatment across the market.

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