memorandum of understanding

The FTC and CFPB have reauthorized their memorandum of understanding.  According to the FTC’s press release, “the agreement reflects the ongoing coordination between the two agencies under the terms of the Consumer Financial Protection Act, and is designed to coordinate efforts to protect consumers and avoid duplication of federal law enforcement and regulatory efforts.”

Taking its inspiration from Elvis Costello’s song lyrics, “peace, love and understanding” is how the FTC describes its “cooperative relationship” with the CFPB in a blog post about the reauthorization of the Memorandum of Understanding (“MOU”) entered into by the two agencies on January 20, 2012.

The MOU had an initial term of three years,

The CFPB and the FTC recently released their long-awaited Memorandum of Understanding (MOU), outlining how they plan to work together on non-bank enforcement, rulemaking and research in the consumer financial services market.  For non-banks subject to the CFPB’s jurisdiction, there is plenty of cause for concern in the MOU, principally arising from the sharing of

The CFPB presented a report this past Monday trumpeting their accomplishments during the implementation period. And, they mention that they have a memorandum of understanding (MOU) in place with just about every transferor agency or other federal agency (i.e., the FTC) with whom they will be working.

Thanks to the misleadingly “open” design of the