CFPB Identifies Preliminary List of Transferred Rules

The Secretary of the Treasury, on behalf of the Consumer Financial Protection Bureau ("CFPB" or "Bureau"), recently published a notice titled "Identification of Enforceable Rules and Orders" (the "Notice") seeking comment on a preliminary list of 47 rules that will be transferred to the Bureau's authority on July 21, 2011, the Dodd-Frank Transfer Date. Although the Dodd-Frank Act transfers enforcement of certain consumer financial protection rules to the Bureau as of the Transfer Date, the Dodd-Frank Act requires the Bureau to publish in the Federal Register a final list of the rules and orders that it will enforce. The Bureau, however, does not appear to consider the publication requirement as definitive of its enforcement authority after the Transfer Date. Rather, the Bureau's list of rules merely confirms its stated priority enforcement areas.