Financial Regulation and Consumer Protection Scholars and Former Regulators

Comments on the Requests for Information (RFIs) Issued by Consumer Financial Protection Bureau Acting Director Mick Mulvaney


On January 26, 2018, Mick Mulvaney, the Acting Director of the Consumer Financial Protection Bureau, launched a call for evidence with a series of Requests for Information that appeared in the Federal Register. These so-called "RFIs" sought public comment on scaling back every core function of the CFPB, from enforcement and supervision to rulemaking and consumer complaints. We are a group of concerned scholars and former regulators, including experts in financial regulation, consumer financial law, and administrative law, that filed responses to the RFIs. Here are our responses.

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Submissions from 2018

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Response Regarding Bureau Guidance and Implementation Support (Docket No. CFPB-2018-0013), Adam J. Levitin and Financial Regulation and Consumer Protection Scholars and Former Regulators

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Response Regarding Bureau Financial Education Programs (Docket No. CFPB-2018-0015), Carly Urban, J. Michael Collins, Stephanie Moulton, and Financial Regulation and Consumer Protection Scholars and Former Regulators

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Response Regarding Inherited Regulations and Inherited Rulemaking Authorities (Docket No. CFPB-2018-0012), Kathleen Engel and Financial Regulation and Consumer Protection Scholars and Former Regulators

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Response Regarding Adopted Regulations (Docket No. CFPB-2018-0011), Patricia McCoy and Financial Regulation and Consumer Protection Scholars and Former Regulators

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Response Regarding Bureau Rulemaking Processes (Docket No. CFPB-2018-0009), Patricia A. McCoy and Financial Regulation and Consumer Protection Scholars and Former Regulators

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Response Regarding Bureau Public Reporting Practices of Consumer Complaint Information (Docket No. CFPB-2018-0006), Pamela Foohey, Angela K. Littwin, Amy J. Schmitz, and Financial Regulation and Consumer Protection Scholars and Former Regulators

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Response Regarding Bureau External Engagements (Docket No. CFPB-2018-0005), Cathy Lesser Mansfield and Financial Regulation and Consumer Protection Scholars and Former Regulators

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Response Regarding Bureau Enforcement Processes (Docket No. CFPB-2018-0003), Christopher L. Peterson and Financial Regulation and Consumer Protection Scholars and Former Regulators

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Response Regarding Bureau Rules of Practice for Adjudication Proceedings (Docket No. CFPB–2018–0002), David Zaring, Jayme Wiebold, and Financial Regulation and Consumer Protection Scholars and Former Regulators

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Response Regarding Bureau Civil Investigative Demands and Associated Processes (Docket No. CFPB-2018-0001), Prentiss Cox, Christopher L. Peterson, and Financial Regulation and Consumer Protection Scholars and Former Regulators