In this paper, CRA’s Adam Gailey and Eric Simms examine trends in Consumer Financial Protection Bureau (CFPB) enforcement actions since the agency’s founding in July 2011, including changes in enforcement volume over time, the consumer products involved, and the top enforcement action foci.
The authors analyze the enforcement activity under each of the directors who served the CFPB since its inception and the civil money penalties collected by fiscal year. Key insights from the article include:
Key takeaways
- The number of enforcement actions undertaken by the CFPB has fluctuated over time and tends to be at its lowest at the start of a new presidential administration.
- CFPB actions also have an inherent lag: each enforcement action typically focuses on alleged activities that occurred 1.5 to 6 years prior to the action being filed. In 80% of the actions the alleged activity started four or more years prior.
- During the time when Brian Johnson (current nominee to the director of the CFPB) was deputy director, the CFPB pursued 34 enforcement actions and collected over $131 million in civil penalties. These included enforcement actions against student and auto loan servicers, payday lenders, banks, and mortgage lenders, among others.
- Over time, the focus of the actions has also varied. For example, mortgage lending has been a constant topic, while actions focusing on deposits have become more common in recent years.
- There is a wide range in civil money penalties collected each year and on any given matter. The average amount is $268 million. The median amount, which is less sensitive to outliers, is $131 million.
To learn what the history of CFPB enforcement actions reveals, read here.
