Consumer Financial Protection Bureau Law Enforcement: An Empirical Review

In the aftermath of the U.S. financial crisis, Congress created a new federal agency — the Consumer Financial Protection Bureau (CFPB) — with the goal of fashioning a more just and efficient American consumer finance market. The CFPB now serves as the U.S. Government’s primary regulator and civil law enforcement agency governing consumer lending, payment systems, debt collection, and other consumer financial services. In its first four years of enforcing federal consumer protection laws, the CFPB has announced over a hundred different law enforcement cases forcing banks and other financial companies to relinquish over $11 billion in customer refunds, forgiven debts, and financial penalties. Drawing upon pleadings, consent orders, settlement agreements, press releases, and other public documents, this Article presents an empirical analysis of the CFPB’s law enforcement track record. In particular, this paper: (1) provides an introduction to the jurisdiction and powers of the CFPB’s Supervision, Enforcement and Fair Lending Division; (2) classifies all of the CFPB’s publicly announced enforcement matters through 2015; and, (3) presents seven notable findings on the CFPB’s public law enforcement program. An appendix listing the CFPB’s publicly announced enforcement cases through 2015 follows