The CFPB's Summer 2023 Supervisory Highlights

The Consumer Financial Protection Bureau's (CFPB or Bureau) Summer 2023 Supervisory Highlights, which discusses key examination findings between July 2022 and March 2023, underscores the Bureau's continuing aggressive interpretations of its authority. In addition to using its "dormant" authority to supervise nonbanks it determines pose "risks to consumers," the Bureau continues to exercise its ever-expansive unfair, deceptive, or abusive acts and practices (UDAAP) authority to enter areas where it traditionally does not have jurisdiction, most recently including regulation of auto dealers, cybersecurity practices, and Telephone Consumer Protection Act (TCPA) provisions approved by multiple circuit courts of appeals.