Client Alerts

Federal Agencies Clarify Method of Determining Institutions Subject to CFPBS Supervision and Enforcement Jurisdiction

November 29, 2011


This Stay Current discusses the recent supervisory statement from the federal banking agencies and the CFPB outlining how the Agencies intend to calculate asset sizes for insured depository institutions and credit unions in determining which institutions will be subject to their respective supervision and enforcement authority with respect to Federal consumer financial law under Dodd-Frank Act (DFA) Sections 1025 and 1026.

Under those provisions, institutions and credit unions with total assets of more than $10 billion and their affiliates would be subject to the CFPB's supervisory and enforcement authority, while institutions and credit unions at or below the $10 billion asset threshold and their affiliates would remain subject to the supervisory and enforcement authority of the federal banking agencies. The Agency guidance is primarily intended to eliminate uncertainty for institutions regarding the identity of their primary supervisor under DFA Sections 1025 and 1026.

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