Financial Services Bulletin: GAO Releases Bank Study and FTC and CFPB Issue MOU


GAO Releases Study on Institutions Exempt from the Definition of "Bank" in BHCA

On Thursday, January 19, 2012, Government Accountability Office (the "GAO") released a study on the institutions exempt from the definition of "bank" under Section 2 of the Bank Holding Company Act.  The study is a requirement of Section 603(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").  Section 603(b) directs the GAO to evaluate exempt institutions in a number of ways, including identifying the number and types of such institutions, determining their connections to commercial firms, and identifying the federal banking agencies responsible for their supervision.  Section 603(b) also instructs the GAO to evaluate the effectiveness of the federal bank regulatory framework applicable to such institutions and the potential consequences of the removal of this exemption.

Read the GAO study

FTC and CFPB Issue MOU Regarding Coordination of Efforts

On Monday, January 23, 2012, the Federal Trade Commission (the "FTC") and the Consumer Financial Protection Bureau (the "CFPB") signed a memorandum of understanding agreeing to coordinate efforts to protect consumers and avoid duplication of federal law enforcement and regulatory efforts.  Section 1024(c)(3) of the Dodd-Frank Act requires the CFPB and the FTC to work together to coordinate their enforcement activities and promote consistent regulatory treatment of consumer financial products and services.

Read the FTC press release

Read the MOU

© 2012 Perkins Coie LLP