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ARTICLE · 07 APRIL 2022

US CFPB Director: Repeat Offenders Should Face Significant Structural Remedies

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In a charged speech delivered on March 28, 2022,1 the director of the Consumer Financial Protection Bureau ("CFPB" or "Bureau"), Rohit Chopra, announced that the Bureau will begin pursuing significant...

United StatesFinance and Banking

In a charged speech delivered on March 28, 2022,1 the director of the Consumer Financial Protection Bureau ("CFPB" or "Bureau"), Rohit Chopra, announced that the Bureau will begin pursuing significant non-monetary, structural remedies against financial service providers who are found to have committed repeated legal violations. Director Chopra indicated that these remedies are required to deter corporate recidivism that is the result of large financial institutions viewing monetary penalties as simply the cost of doing business.

The announcement should be viewed as a warning for financial service providers due to the potential severity of the remedies suggested by the Director. Specifically, Director Chopra signaled that the Bureau will use its statutory authority to seek "limits on the activities or functions of persons"2 to punish repeat offenders and suggested that such powers, whether exercised by the Bureau alone or in concert with other financial regulators,

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