There are some particularly unique aspects of the Consumer Financial Protection Bureau’s (CFPB) $1 billion consent order against Wells Fargo announced April 20. It marks the bureau’s first settlement to reach 10 figures, and it is the first time in recent memory that the agency has cited only one of the three categories of the Dodd-Frank Act provision outlawing unfair, deceptive or abusive act or practices (UDAAP).
Mick Mulvaney’s hard-line view on regulation by enforcement is difficult to reconcile with the CFPB’s UDAAP authority, as it relies largely on a subjective assessment of a company’s actions, something he has opposed about the provision in the past.
Find out what other takeaways can be gleaned from the record enforcement action.