b'OverviewFor so many people and companies, 2020 was a yearSecurity Act (CARES Act), benefits for federal student of uncertainty unlike any other in recent memory. Itloans borrowers, including interest rate reductions was no different for the financial services industry.and the suspension of collection efforts, and changes The biggest uncertainty was COVID-19. The globalto industry-standard credit reporting practices. Much pandemic had a profound effect on every segmentof this relief is scheduled to expire over the coming of the industryfrom credit reporting to mortgagemonths. The process of unwinding this relief, either lendingand every industry stakeholderfromimmediately or, as is likely, after further extensions by financial services companies to consumers tothe incoming Biden administration, will occupy industry regulators. The story for 2021 (hopefully) will beand regulator attention for much of 2021 and beyond.recovery and the aftereffects of the pandemic.The 2020 event that will perhaps have the most To contain the fallout from the crisis, federal and statesignificant long-term impact on the Consumer Financial policymakers moved swiftly to offer financial reliefProtection Bureaus (CFPB, or the Bureau) regulatory to consumers and regulatory relief to companies.and enforcement agenda is the decision by the Consumer finance companies, whose operations wereSupreme Court last summer in Seila Law LLC v. CFPB, and continue to be severely impacted by the virus, hadNo. 19-7. The Supreme Court held that the Dodd-to navigate these unchartered waters and develop newFrank Acts for-cause removal provision for the CFPB systems and adjust their business practices to shiftingDirector violates the separation of powers, as Article consumer demands and regulatory requirements.II of the Constitution vests in the President the power These requirements included, most notably, theto remove federal officials. The Court stopped short mortgage forbearance and foreclosure moratoriumof striking down the entirety of the Dodd-Frank Act, provisions of the Coronavirus Aid, Relief, and Economichowever, holding instead that the for-cause removal provision could be severed from the rest of the statute. The Supreme Courts ruling means that Presidents have the authority to fire the CFPB Director at will, which The 2020 event that will perhaps have themeans that going forward the CFPBs agenda will more most significant long-term impact on thedirectly mirror the current administrations. Immediately following President Bidens inauguration, Director Consumer Financial Protection BureausKraninger submitted her resignation at the Presidents regulatory and enforcement agenda is therequestmeaning that President Biden will not need to test his new authority to nominate her planned decision by the Supreme Court last summersuccessor, Rohit Chopra, to serve as Director of the in Seila Law LLC v. CFPB, No. 19-7. CFPB. Mr. Chopras appointment is likely to radically reshape the CFPBs regulatory and enforcement agenda, a development which we discuss in detail The Supreme Courts ruling means thatthroughout this Review. Presidents have the authority to fire theYet another surprise awaited the industry in 2020: an uptick in CFPB enforcement activity reversed CFPB Director at will, which means thata years-long decline in the number of publicly going forward the CFPBs agenda will moreannounced enforcement actions initiated by federal agencies, even as the number of actions initiated by directly mirror the current administrations. other federal agencies remained relatively flat. The CFPBs publicly announced enforcement actions in 4'