White House Issues Memorandum Urging Federal Agencies to Adopt Protections for Subjects of Enforcement

On August 31, the Office of Information and Regulatory Affairs (OIRA), an arm of the Office of Management and Budget (OMB) within the Executive Branch, issued a memorandum (M-20-31 memorandum) to implement Section 6 of Executive Order 13924, which reflects the Trump administration’s efforts to combat the economic consequences of COVID-19 as well as to address existing gaps in the enforcement framework with broadly-applicable protections for entities that are subject to enforcement. The memorandum, which articulates ten principles for agencies to consider in reviewing their existing procedures, could have implications for civil and administrative enforcement proceedings by the CFPB and other federal financial regulatory agencies, which may have inspired the CFPB’s recent policy statement on applications for early termination of consent orders. To learn more about the M-20-31 memorandum and its impact on financial regulatory agencies, read the LenderLaw Watch blog.