In my post dated August 8, 2011, I took the CFPB to task for saying in its recent Progress report that it had entered into a MOU with the FTC when it had not done so according to Joel Winston, Associate Director of the Division of Financial Practices. I recently learned that the CFPB has entered into a MOU with the FTC, HUD, and DOJ regarding fair lending issues, but that it has not entered into a MOU with the FTC covering broader enforcement issues. That MOU must be entered into by January 21, 2011. There is quite a bit of overlapping jurisdiction between the CFPB and the FTC and it will be very interesting to see how the two agencies resolve this turf issue. In the meantime, my effort to obtain the already existing MOU regarding fair lending has been unsuccessful. I have been told it is not a public document. So I ask, why not?
