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Expert Analysis

No-Action Action: Steps Toward A Better CFPB Policy

By Eric Mogilnicki and Michael Nonaka (March 8, 2018, 11:58 AM EST) -- The new leadership of the Consumer Financial Protection Bureau has committed the bureau to serving consumers and providers of financial services alike. Doing so will require a new approach to using the toolbox given to the bureau by the Dodd-Frank Act. In particular, Director Mick Mulvaney has signaled that enforcement will be a last resort, and that the bureau will instead seek to improve compliance with the law by making clear what the law requires. Clearing pathways to new products and services by recalibrating the bureau's "no-action letter," or NAL, policy is one way the bureau can make good on that promise.[1]...

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