Craig Cowie article takes CFPB to task for not bringing COVID enforcement cases

Craig Cowie of Montana has written Is the CFPB Still on the Beat? The CFPB'S (Non)Response to the COVID-19 Pandemic, 82 Mont. L. Rev. 41 (2021). Here's the conclusion:

More than ten months into a historic pandemic that has wreaked economic devastation, the CFPB—the primary Federal consumer financial protection regulator that was created in response to the last economic crisis—had not taken a single public enforcement action to address the fallout from the pandemic despite thousands upon thousands of consumer complaints and its own knowledge of ongoing problems. The CFPB can—and must—change its enforcement strategy to bring cases now to protect the consumers being harmed during the pandemic. The CFPB cannot solve every problem facing consumers as a result of the pandemic. But it can help keep consumers from falling into an economic abyss while the country addresses its larger problems. By concentrating on unlawful conduct that undermines or evades laws designed to protect consumers during the pandemic, that makes it harder to keep a job, stay in a home, or recover after the pandemic recedes, or that hurts those who are already suffering more, the CFPB can signal to the marketplace that consumer protection laws will be enforced, even during a pandemic, and that the cop is still on the beat.

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