On October 14, 2020, the Consumer Financial Protection
Bureau (" CFPB") announced a series of
organizational changes affecting the Supervision, Enforcement and
Fair Lending Division (SEFL), the result of an organizational
review that began in February of this year. While there are a
number of minor changes that will be implemented, the most
impactful – and most controversial – change is the
creation of the Office of SEFL Policy & Strategy. This
newly created office will have final sign-off on any new research
matters or investigations undertaken by the Office of Enforcement
("Enforcement"). According to the CFPB, these
changes "will increase efficiency, promote role clarity,
reduce friction, establish consistency in policy and strategic
outcomes SEFL-wide, and leverage existing expertise across
SEFL." However, this announcement has had its share of
critics, including U.S. Sen. Sherrod Brown, the ranking member of
the Committee on Banking, Housing, and Urban
