by Jeff Sovern
Mr. Mulvaney has served as interim CFPB director since November 25, or three months and two days. The CFPB has yet to announce commencement of an enforcement action during that period, though it has dismissed an enforcement action. For comparison, during 2016, the Bureau brought 42 enforcement actions, meaning that if it had kept up that pace during Mulvaney's tenure, it would have brought ten or eleven such cases. Mr. Mulvaney pledged to be vigorous and consistent in enforcing consumer law. At least he has kept his promise to be consistent.