FTC and CFPB reauthorize MOU

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The FTC and CFPB have reauthorized their memorandum of understanding.  According to the FTC’s press release, “the agreement reflects the ongoing coordination between the two agencies under the terms of the Consumer Financial Protection Act, and is designed to coordinate efforts to protect consumers and avoid duplication of federal law enforcement and regulatory efforts.”

The first MOU, signed in 2012, had an initial term of three years, and was reauthorized in 2015 for an additional three-year term.  Although some definitional and organizational changes were made to the new MOU, it does not appear to have any material substantive differences from the 2015 MOU.  However, unlike the prior two MOUs which each had a three-year term, the new MOU provides that it “will remain in effect unless superseded by the signed, mutual agreement of the agencies.”

 

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