The Department of Education (ED) has apparently declined a request by 39 members of Congress to reinstate the Memoranda of Understanding (MOUs) between ED and the CFPB.  The members of Congress, including Elizabeth Warren, Bernie Sanders, and Senate Health, Education, Labor and Pensions ranking Democratic member Patty Murray, penned a September 14th letter just one

Consumer Financial Protection Bureau (CFPB) Director Richard Cordray has responded to the letter from the Department of Education (ED) terminating the Memoranda of Understanding (MOUs) between the agencies. ED’s August 31st letter—signed only by Kathleen Smith of the Office of Postsecondary Education and Dr. A. Wayne Johnson of Federal Student Aid—provided 30 days’ notice

The Department of Education (ED) recently delivered a letter to the Consumer Financial Protection Bureau (CFPB) providing notice of its intent to terminate the Memoranda of Understanding (MOUs) between the agencies. The letter is highly critical of the CFPB. The sharp rebuke proclaims ED’s “full oversight responsibility of federal loans” and does not explicitly salvage

On December 6, 2012, the CFPB and the Department of Justice (“DOJ”) executed a Memorandum of Understanding (“MOU”) aimed at strengthening their coordination in connection with fair lending investigations. The MOU also seeks to avoid duplication of the agencies’ respective enforcement efforts, particularly with regard to coordinating investigations of alleged violations of the Equal Credit

A hearing entitled “How will the CFPB Function under Richard Cordray?” was held on January 24 by the House Subcommittee on TARP, Financial Services and Bailouts of Public and Private Programs. At that hearing, Mr. Cordray testified that Congress’s failure to amend 12 U.S.C. § 1828(x) to include the Bureau was an oversight and that

As we reported in an earlier posting, it has taken considerable effort to locate the memoranda of understanding (MOUs) that the CFPB has put in place with various other federal agencies. More of those MOUs recently surfaced through, we believe, a Freedom of Information Act (FOIA) request. One of the newly uncovered MOUs is

At the American Bar Association’s Annual Meeting in Toronto, I attended a two-hour program on August 6 about the CFPB.  I was disturbed by two things that occurred at that meeting, which made me question again whether the CFPB is as transparent as it says it is. 

First, the CFPB would not permit anyone on

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