“What’s so funny ‘bout peace, love, and understanding?” Elvis Costello asked that musical question back in the day. The Memorandum of Understanding between the FTC and CFPB – which the two agencies just reauthorized for a three-year period – shows that when it comes to protecting consumers, ensuring a vibrant marketplace for financial products and services, and using resources efficiently, we're in harmony.
The Interagency Cooperation Agreement has been in place since 2012. Aside from a few small administrative tweaks, the new document signed by Chairwoman Ramirez and Director Cordray reflects how we’ve been working together all along. If you or your clients are within the jurisdiction of the FTC or CFPB, it offers a refresher on the steps we take to get the job done efficiently and cooperatively. Here are some highlights:
- Law enforcement. We aim to coordinate our efforts to protect consumers from illegal practices while avoiding unnecessary burdens on business. To that end, we let each other know about companies we’re planning to investigate and do our best to use resources efficiently. We also share lists of entities subject to orders or judgments.
- Rulemaking and guidelines. We keep the lines of communication open about planned or ongoing rulemakings and industry guidance.
- Consumer complaints. We share consumer complaints about financial products and services. CFPB’s participation in the FTC-administered Consumer Sentinel Network is an important part of that. We also work together to make sure consumers with a concern get routed to the right agency.
- Research. We meet periodically to discuss ongoing research and share the results before any public announcement.
- Consumer education. We talk at least quarterly about what we’re doing to educate consumers, including the special financial issues facing military families and older Americans.
- Operational planning. We talk over big-picture matters at least twice a year. The kind of things we discuss: emerging issues consumers face in the financial marketplace, the remedies we use, and task forces or working groups we participate in.
- Information sharing and confidentiality. We follow set procedures to maintain the confidentiality of nonpublic information and appropriately address third-party requests for information.
Elvis Costello ended “Peace, Love, and Understanding” with these questions:
So where are the strong?
Who are the trusted?
And where is the harmony?”
Based on the principles in the Memorandum of Understanding, we’d answer this way:
Companies that comply with the law.
And the cooperative relationship between the FTC and CFPB.