CFPB 2.0: Advancing Consumer Protection

Read the Original CFPB 2.0 Whitepaper

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CFPB 2.0

This white paper, prepared by MBA and its counsel at the law firm of Covington & Burling LLP.

Over the years, the Consumer Financial Protection Bureau (CFPB) has grown from a small startup to a powerful agency with over 1,600 employees. Over the same period, the economy and our financial and political institutions have also been transformed. Accordingly, it makes sense to take a fresh look at the Bureau and see how it should evolve to reflect these changes as well as its own successes and challenges. This MBA has provided recommendations to explain how an updated Bureau - call it CFPB 2.0 - could advance consumer protection while promoting a vibrant, competitive mortgage lending market.

The Roadmap to CFPB 2.0

A response to the 2018 CFPB requests for information ("RFIs") aimed at soliciting comments on Bureau practices and consumer financial laws.

MBA responded to these RFIs with detailed recommendations on how the Bureau can better align both its supervisory practices and the regulations it administers with its statutory mandate and generally accepted principles of sound prudential regulation. This paper uses MBA's recommendations from those specific RFIs to construct a plan, or "road map," to guide the Bureau in making much needed reforms without sacrificing consumer protections.

The key recommendations are organized by: 

  • Rulemaking
  • Enforcement
  • Supervision
  • Market Monitoring
  • Regulations

Looking Forward

MBA and its members are committed to compliance, consumer protection and to a level playing field for all who offer mortgages and related services to consumers. In offering this "road map," we seek to create a safe and inclusive mortgage market with clear rules of the road and robust consumer protections.