The Federal Trade Commission ("FTC") and Consumer
Financial Protection Bureau ("CFPB") have renewed their
vow to continue to coordinate their activities and avoid
duplication of federal law enforcement and regulatory
efforts. The FTC and CFPB have recently announced they
reauthorized their ongoing Memorandum of Understanding ("MOU"),
under the terms of the Consumer Financial Protection Act
("Act"), to coordinate efforts to protect consumers and
avoid duplication of federal law enforcement and regulatory
efforts, for three years.
As you may recall, back when the Dodd-Frank Act passed, there
was much discussion about the potential for overlap between the FTC
and CFPB's jurisdiction to regulate and enforce consumer
financial services laws. The resulting act significantly
altered the consumer financial protection landscape by
consolidating rulemaking authority and, to a lesser extent,
supervisory and enforcement authority in one regulator—the
CFPB. In contrast, the
