Alert November 29, 2011

CFPB Asks for Comments on Collecting Information Concerning State Actions Pursuant to Dodd-Frank

The Consumer Financial Protection Bureau published a notice and request for comment regarding its plans to collect information about legal actions filed by state officials under authority granted in Section 1042(a) of the Dodd-Frank Act. This Section provides state attorneys general and state regulators with authority to bring legal actions against financial institutions to enforce provisions of Title X of Dodd-Frank and its implementing regulations. The Bureau published an interim final rule in July of this year establishing the notification procedures regarding state legal action taken.  In the current notice, the Bureau states that the burden of providing information on actions taken falls on the state authorities and that the Bureau does not expect to make this information publicly available unless already made available by the state reporting the action.  The Bureau is asking for comment on a number related questions, including whether collecting this information is necessary for the "proper performance" of the Bureau and whether the information will have "practical utility."  Click here for the notice.