Which One of Us Is the Service Provider? The Dodd-Frank Act's Infinite Loop of Oversight (PDF)
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A centerpiece of CFPB supervision is service provider oversight but assigning roles is not always straightforward. A lack of clarity may lead to duplicative, simultaneous oversight. While there is substantial guidance as to the what in service provider oversight, there is little guidance as to the who. In this analysis, Valerie L. Hletko and Sarah E. Hager of BuckleySandler LLP offer a way out of the infinite oversight loop.
VALERIE L. HLETKO is a Partner and SARAH E. HAGER is a Regulatory Attorney with the Washington, D.C. office of BuckleySandler LLP. They represent financial services companies in connection with government enforcement proceedings, including those of the CFPB, in regulatory examinations, investigations, and litigation. The authors’ e-mail addresses are email@example.com and firstname.lastname@example.org.
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