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The Large Bank Protection Act: Raising the CFPB’S Enforcement and Supervision Asset Threshold Would Place American Consumers at Risk Christopher L

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The Large Bank Protection Act: Raising the CFPB’S Enforcement and Supervision Asset Threshold Would Place American Consumers at Risk Christopher L The Large Bank Protection Act: Raising the CFPB’s Enforcement and Supervision Asset Threshold Would Place American Consumers at Risk Christopher L. Peterson May 3, 2018 1620 Eye Street, NW, Suite 200 | Washington, DC 20006 | (202) 387-6121 | consumerfed.org Executive Summary Congress is currently considering raising the total asset threshold for Consumer Financial Protection Bureau (CFPB) supervision and enforcement of banks from $10 billion to $50 billion. This report analyzes the effect of this change on the number of banks subject to CFPB oversight. Furthermore, this report looks at the CFPB’s enforcement track record in cases against banks within the $10-to-$50-billion-range, and highlights examples of enforcement actions previously taken by the CFPB that would have been impossible if the asset threshold were set at $50 billion under the original Dodd-Frank Act. Raising the CFPB supervision and enforcement threshold from ten to fifty billion dollars would: • Cut the number of banks subject to CFPB supervision and enforcement by 65% from 124 to 43. Currently, 124 out of 5,679 banks are subject to CFPB enforcement. Raising the CFPB oversight threshold to fifty billion dollars would place 81 of the nation’s largest banks beyond the supervisory and enforcement jurisdiction of the CFPB. • Eliminate CFPB oversight of nearly 50 of the largest banks bailed out during the financial crisis. Forty-nine of 81 large banks in the $10 to $50 billion asset range took TARP funds during the Great Recession. After bailing out these banks with taxpayer money, Congress is now considering removing them from the supervision and enforcement authority of the agency designed to prevent some of the same behavior that caused the crisis. • Eliminate critical CFPB law enforcement cases against large banks that violate federal law. Past CFPB cases that would have been impossible under the proposed $50 billion threshold involved illegal activity like: o Widespread “redlining” in the Northeast, resulting in the largest redlining settlement in history that provided subsidies to borrowers in redlined neighborhoods as a form of consumer relief. o Widespread “redlining” in the Memphis area, where Black home mortgage borrowers were charged over $300 more annually than similarly situated White borrowers and Black loan applicants were denied more than twice as often for mortgages as White applicants. o Unfair home mortgage collection practices that illegally railroaded families into foreclosures and short sales. o Signing up customers for credit card “add-on” products they did not request and charging customers for credit monitoring services they did not receive. o Denying bank customers the full value of funds deposited into their checking and savings accounts. These cases show that it is not large banks that need protection from the CFPB, but ordinary Americans who need protection from illegal financial practices at some large banks, including those with between $10 billion and $50 billion in assets. The Large Bank Protection Act | Consumer Federation of America 2 Background Congress created the Consumer Financial Protection Bureau (CFPB) in the wake of the largest financial crisis since the Great Depression. When residential mortgage backed securities proved worthless, investors all across the world took horrendous financial losses. Most of large American banks collapsed, forcing Congress and the Board of Governors of the Federal Reserve System to bail out the financial sector. In response to this crisis, Congress adopted the Dodd-Frank Wall Street Reform and Consumer Protection Act which transferred regulatory and primary enforcement authority over the nation’s consumer financial protection laws to the newly created Consumer Financial Protection Bureau. While the Dodd-Frank Act has been controversial in some respects, the CFPB has focused on ensuring consumer financial services offered to the public are transparent and fair. This mission, and the CFPB itself, are overwhelmingly popular with the public including Republicans, Independents, and Democrats.1 The CFPB’s supervision and law enforcement responsibilities have been implemented through the Bureau’s Supervision, Enforcement, and Fair Lending Division (SEFL).2 The CFPB has supervisory authority over large banks and credit unions with over $10 billion in assets, as well as other supervised non-bank consumer finance businesses specified by Congress or Bureau regulations.3 Non-bank consumer finance companies subject to supervision include mortgage originators, brokers, servicers, and foreclosure assistance providers; private student loan originators and student loan servicers; and payday lenders. The Bureau has also issued regulations asserting supervisory jurisdiction over certain large financial companies, including consumer reporting agencies, debt collection businesses, international remittance providers, and automobile finance companies.4 CFPB supervisory staff conduct risk-based examinations that audit supervised business to ensure compliance with consumer financial protection laws. The Bureau’s supervisory staff publishes an examination manual to assist companies in preparing for exams. In past years, CFPB supervisory staff also regularly published a Supervisory Highlights report sharing public results of the examiners’ work.5 Examinations remain confidential unless the exam uncovers evidence of serious violations of the law requiring referral of the company to the Bureau’s Office of Enforcement. The CFPB’s Office of Enforcement has the mission of enforcing consumer financial laws. Enforcement investigations arise either from supervisory exams or when staff uncover suspected violations of consumer protection law through consumer complaints, referrals from state or federal regulators, or other sources of information. As with supervision, the CFPB’s Enforcement Office has enforcement jurisdiction over banks and credit unions with more than $10 billion in assets.6 With respect to non-banks, the Bureau has enforcement jurisdiction over any “covered person” or “service provider” to a covered person, other than automobile dealers that do not routinely engage in “buy-here, pay-here” financing, as well as a short list of 1 See Celinda Lake, Bob Carpenter, David Mermin, and Zoe Grotophorst, New Poll Reveals Strong Bipartisan Support for Financial Regulation; Americans Say Wall Street’s Influence in Washington is Too High (July 18, 2017), available athttp://ourfinancialsecurity.org/2017/07/afrcrl-polling-memo-fifth-consecutive-year-broad-backing-cfpb-wall-street- reform/ (finding that 77 percent of independents and 66 percent of Republicans “favor somewhat” or “favor strongly” the CFPB). 2 Recently Mick Mulvaney, President Trump’s designee as CFPB Acting Director, has announced plans to close the Office of Fair Lending and Equal Opportunity and fold its staff into a human resources-oriented equal opportunity office. Kate Berry, CFPB's Mulvaney Strips His Fair-lending Office of Enforcement Powers, AMERICAN BANKER, Feb. 1, 2018, https://www.americanbanker.com/news/cfpbs-mulvaney-strips-his-fair-lending-office-of-enforcement-powers. 3 12 U.S.C.. §§ 5514(b), 5515(b). 4 12 C.F.R. §§ 1090.104-1090.108. 5 See CONSUMER FINANCIAL PROTECTION BUREAU, CFPB SUPERVISION AND EXAMINATION MANUAL, (March 2017), https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201706_cfpb_supervision-and-examination- manual.pdf; Consumer Financial Protection Bureau, Supervisory Highlights, Issue 15, Spring 2017. 6 12 U.S.C. §§ 5514(c), 5515(c). The Large Bank Protection Act | Consumer Federation of America 3 other specifically excluded businesses.7 Congress authorized the CFPB to enforce federal consumer financial laws either through administrative enforcement cases brought before an administrative law judge or through its own authority to litigate in federal court.8 Administrative enforcement actions are conducted under a CFPB regulation that largely mirrors similar enforcement agencies, with trials before an administrative law judge and decisions reviewable on appeal to the Bureau’s Director.9 In both administrative proceedings and civil litigation, Congress authorized the CFPB to seek any appropriate legal or equitable relief including restitution, disgorgement, and civil money penalties from businesses and individuals that violate federal law.10 In recent years, some members of Congress have argued that CFPB supervisory and enforcement jurisdiction over banks and credit unions should be decreased by raising the total asset threshold from ten billion dollars to fifty billion dollars. Most notably, H.R. 3072, The Bureau of Consumer Financial Protection Examination and Reporting Threshold Act of 2017, sponsored by Rep. Lacy Clay (D–MO), would implement such a change by striking $10 billion from 12 U.S.C. § 5515(a) and replacing it with a threshold of $50 billion. This report responds both to H.R. 3072 in particular as well as similar future proposals that may seek to raise asset threshold for CFPB supervision of and enforcement against banks. CFPB Supervision and Enforcement Jurisdiction by the Numbers: Large and Very Large Banks Under current law, the CFPB has supervision and enforcement authority over banks only if the bank has total assets exceeding $10 billion.11 This threshold leaves the CFPB with a relatively small supervision and enforcement footprint in terms of the actual number of banks subject to its oversight. According to 2017 FDIC data, America has 5,679 banks. Figure 1 illustrates that out of these institutions,
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